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D. Minn.Procedural orderFiled July 10, 2018

Brown v. Cooper

Judge
David Doty
Docket
0:18-cv-00219
Court
U.S. District Court · District of Minnesota
Pages
2
Civil ProcedureTort
In one sentence

In Brown v. Cooper, Judge Thorson granted the United States’ motion to replace federal employees as defendants on the Federal Tort Claims Act claim.

Who this affects

The United States and the federal employees named as defendants in Claim Five; the substitution applied only to Claim Five of James N. Brown, Jr.’s amended complaint.

What happened

In Brown v. Cooper, the United States asked to be substituted for the federal employees named in Claim Five of James N. Brown, Jr.’s amended complaint. Claim Five sought money damages and injunctive relief under the Federal Tort Claims Act.

The court explained that federal employees cannot be named as defendants in a Federal Tort Claims Act case. The United States is the proper defendant instead. No party responded to the motion within the time allowed by the local rules.

Judge Becky R. Thorson granted the motion and substituted the United States for the federal defendants as to Claim Five.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Brown v. Cooper · No. 0:18-cv-00219
Judge
David Doty
Date
July 10, 2018

Background

The United States moved to substitute itself as the defendant for the federal employees named in Claim Five of James N. Brown, Jr.’s amended complaint. The motion concerned the federal defendants identified in the order, including G. Cooper, Ken Hyle, Kathleen Kenny, Sara Revell, L. LaRiva, C. Orum, A. Cossette, R. Woltman, M. Porter, L. Janssen, D. Holbus, C. Stromberg, Hare, Charles Slater, Peter Arroyo, and Sheila Hadaway. No party responded within the time allowed by the local rules.

Claim and legal standard

Claim Five sought money damages and injunctive relief under the Federal Tort Claims Act. The court relied on Supreme Court and Eighth Circuit precedent stating that federal employees cannot be named as defendants in a Federal Tort Claims Act action and that the United States is the proper defendant.

Ruling

The court granted the Motion to Substitute the United States of America for Federal Defendants as to Claim Five. Judge Becky R. Thorson therefore ordered that the United States replace the specified federal defendants with respect to that claim.

The authoritative version

Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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