SAN FRANCISCO - A federal district court did not err in dismissing a lawsuit brought by investors in Bernard L. Madoff's massive Ponzi scheme for lack of jurisdiction because the investors' claims are incapable of overcoming the "discretionary function exception to the Federal Tort Claims Act's waiver of sovereign immunity," a Ninth Circuit U.S. Court of Appeals panel ruled Jan. 28 (Dichter-Mad Family Partners LLP, et al. v. United States of America, No. 11-55577, 9th Cir.; 2013 U.S. App. LEXIS 1926).