The US Supreme Court ruled Thursday that a Michigan college student is unable to proceed with a Federal Tort Claims Act (FTCA) lawsuit against two federal officers who tackled him after mistaking him for a fugitive in 2014. In a unanimous ruling, the Supreme Court found that the claims against the officers have been disqualified for suit under the FTCA’s “judgment bar” and that the officers are immune from liability for the damages inflicted while undertaking their official duties in good faith.
The student, James King, was a Grand Valley State University student who thought he was being mugged when two plainclothes federal joint task force agents approached him in Grand Rapids. King alleges that the officers did not identify themselves as law enforcement, and he fought back when they attempted to violently detain him, resulting in King’s hospitalization. The agents maintain that they identified themselves appropriately, that they informed King they were looking for a suspect on a felony warrant, and that he became verbally combative and aggressive.
Following King’s arrest, a jury found him not guilty of resisting and obstructing police, causing injury and felonious assault. King then filed suit in federal district court under the FTCA, alleging that the officers committed six torts under Michigan law. He also sued the officers individually under a Bivens action, claiming four violations of his Fourth Amendment rights.
The district court granted a motion for summary judgment in favor of the defendants on King’s FTCA claims, finding a lack of subject matter jurisdiction because the officers did not act with malice, which would provide them with qualified immunity based on Michigan tort law. The district court then dismissed King’s Bivens claims, ruling that the FTCA’s statutory “judgment bar” meant the officers could not be sued for damages based on facts that have already received a judgment. King appealed the dismissal of his Bivens claims. The US Court of Appeals for the Sixth Circuit ruled that the dismissal of the FTCA claims did not trigger the judgment bar on recovery under the parallel Bivens claims because the district court had dismissed the FTCA claims due to a lack of subject matter jurisdiction and not on the merits. The Sixth Circuit held that the defendants were not entitled to qualified immunity and reversed the district court’s ruling.
Writing for a unanimous court, Justice Clarence Thomas found that the district court’s summary judgment was satisfactory to trigger the judgment bar, as it passed directly on the merits of King’s FTCA claims, even though the court lacked subject matter jurisdiction. By finding that a dismissal for lack of jurisdiction still constituted a judgment on the merits of the case, the Supreme Court ruled that the judgment bar applied to any subsequent suits King filed for damages. However, the Supreme Court did not rule on whether the government could obtain judgment bar immunity from a single lawsuit containing both constitutional and tort claims, which Justice Sonia Sotomayor stated in a concurrence deserved “much closer analysis.” The case now returns to the Sixth Circuit for further consideration on this issue.
