Searles v. United States

Background

Jared Searles alleged that multiple fellow inmates assaulted and stabbed him on July 5, 2020, while he was in the custody of the Bureau of Prisons at the Metropolitan Correctional Center. He alleged that correctional officers and other staff knew about improper inmate behavior, failed to provide adequate security, and failed to take steps to prevent or warn about an unsafe housing area. He also alleged that the staff were unfit or incompetent and had not been properly hired, retained, or trained.

Searles brought claims against the United States under the Federal Tort Claims Act for negligent hiring, training, retention, and entrustment; negligent infliction of emotional distress; intentional infliction of emotional distress; assault; and battery. The United States moved to dismiss under Federal Rule of Civil Procedure 12(b)(1), which challenges the court’s subject-matter jurisdiction, and Rule 12(b)(6), which challenges whether the complaint states a legally sufficient claim.

Assault and Battery Claims

The court held that it lacked jurisdiction over the assault and battery claims. The Federal Tort Claims Act generally preserves the United States’ immunity from claims arising from assault or battery, subject to an exception for certain intentional acts by federal law-enforcement officers. Searles alleged that fellow inmates—not federal officers—assaulted him. He did not allege that a law-enforcement officer intentionally placed him in fear of harmful contact or intentionally subjected him to harmful contact. The court therefore found no basis for jurisdiction over those claims.

Negligence Claims

The court dismissed the negligent hiring, training, retention, and entrustment claims, as well as the negligent-infliction-of-emotional-distress claim, for lack of subject-matter jurisdiction under the Federal Tort Claims Act’s discretionary-function exception. That exception protects government conduct involving judgment or choice when the conduct is grounded in public-policy considerations.

The court concluded that decisions about prison security, including how much security to provide and how to provide it, involve discretion. It also concluded that hiring, training, supervision, and retention decisions generally involve policy judgments. The statute requiring the Bureau of Prisons to manage federal correctional institutions and provide for prisoners’ safekeeping did not prescribe specific methods for carrying out those responsibilities.

The court rejected Searles’s reliance on the negligent-guard theory. That theory can apply when prison employees carelessly or lazily fail to carry out discretionary duties, rather than when the challenged claim attacks the discretionary policy itself. The court found that Searles had not alleged that an employee’s carelessness or laziness in carrying out duties caused his injuries. The court also noted that the complaint did not allege facts showing that the staffing policy fell outside the range of appropriate judgment or that employees failed to follow specific regulations.

The court stated that the negligence claims would also fail under Rule 12(b)(6) because Searles did not allege facts about how the government hired, screened, or trained the relevant correctional personnel. The negligent-infliction claim also lacked a plausible allegation that the government breached a duty based on a reasonably foreseeable risk. Although Searles alleged that staff knew about improper inmate behavior and failed to prevent or warn about an unsafe area, he did not explain what made the area unsafe, what the inmates were doing, or how staff could have known that particular inmates posed a danger.

Intentional Infliction of Emotional Distress

The court dismissed the intentional-infliction-of-emotional-distress claim under Rule 12(b)(6). Under New York law, that claim requires extreme and outrageous conduct, intent to cause or disregard of a substantial possibility of causing severe emotional distress, a connection between the conduct and the injury, and severe emotional distress. The court found that Searles’s complaint contained only conclusory statements and did not plausibly allege sufficiently extreme conduct or the required intent.

Disposition

The court granted the United States’ motion to dismiss and dismissed the case in its entirety. It granted Searles leave to amend because additional facts might remedy some of the identified deficiencies, including facts showing careless enforcement of a security policy or a policy outside the range of appropriate judgment. Any amended complaint had to be filed within 30 days, and the court stated that amendment must have a good-faith basis.