In Carlson v. Green, 446 U.S. 14, 100 S.Ct. 1468, 64 L.Ed.2d 15 (1980), the plaintiff brought a Bivens action alleging that a federal prison official had violated her deceased son's constitutional rights by failing to provide proper medical attention. The Court discussed at length whether the plaintiff's available remedy under the Federal Tort Claims Act (FTCA) precluded her from bringing a Bivens action. After reviewing the Congressional comments accompanying the 1974 amendments to the FTCA, the Court concluded that it was "crystal clear that Congress views FTCA and Bivens as parallel, complementary causes of action." 446 U.S. at 20, 100 S.Ct. at 1472. The Court went on to hold that, in the absence of an explicit expression from Congress to the contrary, a victim of wrongdoing by a federal official has an action against the Government under the FTCA as well as a Bivens action against the individual official. The Court expanded the law created by Bivens and Davis still further. A mother sued for damages allegedly caused by federal prison officials' violation of her deceased son's constitutional rights protected by the Eighth Amendment. The Court held that a tort remedy was "available directly under the Constitution," even though the allegations could also support a suit under the Federal Tort Claims Act. That holding made clear that a Bivens-type suit can exist even where other remedies are available. The Court interpreted the Bivens holding in a sweeping manner: "Bivens established that the victims of a constitutional violation by a federal agent have a right to recover damages against the official in federal court despite the absence of any statute conferring such a right. Such a cause of action may be defeated in a particular case, however, in two situations. The first is when defendants demonstrate "special factors counselling hesitation in the absence of affirmative action by Congress." 403 U.S., at 396 91 S.Ct., at 2004; Davis v. Passman, 442 U.S. 228, 245 99 S.Ct. 2264, 2277, 60 L.Ed.2d 846 (1979). The second is when defendants show that Congress has provided an alternative remedy which it explicitly declared to be a substitute for recovery directly under the Constitution and viewed as equally effective. Bivens, supra 403 U.S. at 397 91 S.Ct. at 2005; Davis v. Passman, supra 442 U.S. at 245-247 99 S.Ct. at 2277-2278." (446 U.S. at 18-19, 100 S.Ct. at 1471.)