Will v. Hallock, 546 U.S. 345 (2006)
Primary Holding
The 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.
In the case of Will v. Hallock, the Supreme Court decided that when a court refuses to apply a certain legal protection (the judgment bar) in a case against the government, that decision cannot be appealed right away. This matters because it clarifies how and when people can challenge government actions that cause harm, ensuring that they have to wait until a final decision is made before appealing. For consumers, this ruling emphasizes that while they can seek justice for damages caused by government actions, they may have to navigate specific legal processes and timelines before they can appeal decisions. This case is relevant if someone is trying to sue the government for damages and faces a dismissal based on legal protections; they should be aware that they might not be able to appeal until the entire case is resolved.
AI-generated plain-language summary to help you understand this case
In the case of Will v. Hallock, the underlying dispute arose from an incident involving Susan Hallock and her husband, Richard Hallock, who operated a computer software business from their home. The couple became victims of credit card fraud when Richard's credit card information was stolen and used to pay for a subscription to a child pornography website. In response, agents from the United States Customs Service obtained a warrant to search the Hallocks' residence, during which they seized the couple's computer equipment and software. Upon the return of the equipment, the Hallocks discovered that several disk drives were damaged, resulting in the loss of critical data, including trade secrets and account files, which ultimately forced them out of business. Procedurally, Susan Hallock and her company filed a lawsuit against the United States under the Federal Tort Claims Act (FTCA) in July 2002, claiming negligence by the customs agents during the execution of the search. However, the District Court dismissed the case without addressing its merits, ruling that the agents' actions fell within an exception to the FTCA's waiver of sovereign immunity. Following this dismissal, Hallock initiated a separate action against the individual agents under Bivens, alleging that their actions constituted a violation of her property rights under the Fifth Amendment. The agents responded by invoking the judgment bar of the FTCA, which would preclude her claim against them based on the same subject matter. The District Court denied their motion, leading to an appeal. The Court of Appeals for the Second Circuit affirmed the District Court's decision, asserting jurisdiction under the collateral order doctrine. The Supreme Court subsequently granted certiorari to address the issue of whether the judgment bar of the FTCA could be appealed in this context. Ultimately, the Supreme Court vacated the lower court's ruling, determining that it lacked appellate jurisdiction over the matter.
Whether a refusal to apply the judgment bar of the Federal Tort Claims Act is open to collateral appeal.
The judgment of the Court of Appeals is vacated and the case is remanded with instructions to dismiss the appeal for lack of jurisdiction.
- Court
- Supreme Court
- Decision Date
- November 28, 2005
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Souter
- Damages Awarded
- N/A
- Data Quality
- high
United States v. Olson, 546 U.S. 43 (2005)
Mixed OutcomeThe Federal Tort Claims Act (FTCA) waives sovereign immunity only in circumstances where the United States would be liable as a "private person" under local law, not based on the liability of state or municipal entities.
Dolan v. Postal Service, 546 U.S. 481 (2006)
Consumer WonThe Supreme Court held that the Federal Tort Claims Act (FTCA) waives sovereign immunity for the United States Postal Service in cases of negligence, allowing claims to proceed even when certain exceptions might apply, thus permitting Barbara Dolan's suit against the Postal Service to move forward.
Mohawk Industries, Inc. v. Williams, 547 U.S. 516 (2006)
Mixed OutcomeThe Supreme Court dismissed the writ of certiorari as improvidently granted, indicating that the case was not suitable for review at that time, and remanded it for further consideration in light of a related decision.
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.