Law School Case Brief
Coulthurst v. United States - 214 F.3d 106 (2d Cir. 2000)
28 U.S.C.S. § 1346(b)(1) of the Federal Tort Claims Act authorizes suits against the government to recover damages for injury or loss of property, or personal injury or death caused by the negligent or wrongful act or omission of any employee of the Government while acting within the scope of his office or employment, under circumstances where the United States, if a private person, would be liable to the claimant in accordance with the law of the place where the act or omission occurred.
Plaintiff Doreell Coulthurst, a federal prisoner incarcerated at the Federal Corrections Institute in Connecticut, suffered injuries to his shoulders, neck, and back while lifting weights in the prison gymnasium, when a cable snapped on a lateral-pull down machine. Coulthurst brought suit against the United States under the Federal Tort Claims Act ("FTCA"), seeking to recover damages for his injuries caused by the government's negligence in maintenance of the weight room. The United States District Court for the District of Connecticut granted the government's motion to dismiss the complaint for lack of subject matter jurisdiction, on the ground that, pursuant to the discretionary function exception ("DFE") to the FTCA, the United States was immune from suit for the type of conduct alleged in the complaint. Plaintiff appealed, arguing that the complaint can fairly be read to allege conduct which fell outside the scope of DFE.
Did the plaintiff injured federal prisoner's complaint under the Federal Tort Claims Act encompass conduct which falls outside the scope of the discretionary function exception?
While generally, the United States was immune from suit except to the extent the government has waived its immunity, 28 U.S.C.S. § 1346(b)(1) of the Federal Tort Claims Act authorized suits against the government to recover damages for injury or loss of property, or personal injury or death for conducts which fall outside the discretionary function exception. In the case at bar, the Court held that the complaint fairly alleged negligence outside the scope of the discretionary function exception. Accordingly, the Court held that the dismissal on the basis of the allegations of the plaintiff’s complaint was inappropriate. The Court vacated the judgment of dismissal.
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