Ali v. Federal Bureau of Prisons, 552 U.S. 214 (2008)
Primary Holding
The phrase "any other law enforcement officer" in 28 U.S.C. §2680(c) encompasses all law enforcement officers, thereby barring claims against the United States for property damage or loss resulting from the actions of federal prison officials under the Federal Tort Claims Act.
In the case of Ali v. Federal Bureau of Prisons, a federal prisoner named Abdus-Shahid Ali lost some of his personal belongings while being transferred to another prison. He tried to sue the government for the missing items, but the Supreme Court ruled that federal prison officials are considered law enforcement officers, which means he couldn't file a claim against the government for his lost property. This ruling is important because it clarifies that consumers can't hold the government responsible for property loss or damage caused by law enforcement actions, including those by prison staff. If someone finds themselves in a similar situation, like losing personal items while in custody, this case shows that they may not have legal recourse to recover those losses from the government.
AI-generated plain-language summary to help you understand this case
In *Ali v. Federal Bureau of Prisons*, Abdus-Shahid M. S. Ali was a federal prisoner at the United States Penitentiary in Atlanta, Georgia, from 2001 to 2003. In December 2003, prior to his transfer to the United States Penitentiary Big Sandy in Kentucky, he left two duffle bags containing personal property at the Atlanta prison for inventory and shipping. Upon arrival at USP Big Sandy, Ali discovered that several items, including religious items of significant personal value, were missing. He was informed by the staff that he could file a claim regarding the missing items, which he estimated to be worth $177. After filing an administrative tort claim, the Federal Bureau of Prisons (BOP) denied relief, citing that Ali had certified the accuracy of the inventory upon signing the receipt form, thereby relinquishing any future claims for missing or damaged property. Ali subsequently filed a complaint under the Federal Tort Claims Act (FTCA), asserting violations related to the missing property. The BOP contended that his claim was barred by the exception in 28 U.S.C. §2680(c), which excludes claims arising from the detention of property by law enforcement officers. The District Court dismissed Ali's claim for lack of subject-matter jurisdiction, agreeing with the BOP's interpretation of the statute. Ali appealed the District Court's decision, and the Eleventh Circuit affirmed the dismissal, aligning with the interpretation of §2680(c) as it pertains to law enforcement officers. The Eleventh Circuit referenced previous Supreme Court rulings and decisions from other Courts of Appeals to support its conclusion. The Supreme Court granted certiorari to address the disagreement among the Courts of Appeals regarding the scope of §2680(c), ultimately affirming the lower court's judgment.
Whether the exception in 28 U.S.C. §2680(c) for claims arising from the detention of property by "any officer of customs or excise or any other law enforcement officer" applies to claims against officers of the Federal Bureau of Prisons under the Federal Tort Claims Act.
The judgment is reversed.
- Court
- Supreme Court
- Decision Date
- October 29, 2007
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Thomas
- Damages Awarded
- N/A
- Data Quality
- high
Will v. Hallock, 546 U.S. 345 (2006)
Consumer LostThe refusal to apply the judgment bar of the Federal Tort Claims Act is not subject to collateral appeal, as it does not constitute a final decision under 28 U.S.C. §1291.
Wilkinson v. Dotson, 544 U.S. 74 (2005)
Consumer WonPrisoners may bring actions under 42 U.S.C. §1983 to challenge the constitutionality of state parole procedures, rather than being required to seek relief exclusively through federal habeas corpus statutes.
Allen v. Siebert, 552 U.S. 3 (2007)
Consumer LostA state postconviction petition rejected by the state court as untimely is not considered "properly filed" under 28 U.S.C. § 2244(d)(2), and thus does not toll the one-year statute of limitations for filing a federal habeas petition.
Whitman v. Department of Transportation, 547 U.S. 512 (2006)
Mixed OutcomeThe Court held that the jurisdiction of federal courts to review employment-related claims of federal employees is not conferred by 5 U.S.C. §7121(a)(1), but such jurisdiction is not divested by the Civil Service Reform Act (CSRA), allowing for potential claims to be pursued under 28 U.S.C. §1331 if they arise under the Constitution or federal law.