Hart v. United States of America (INMATE 1)

Federal inmate Darrell Hart, proceeding pro se, filed a lawsuit against the United States alleging negligence after he was assaulted by another inmate at a Bureau of Prisons facility. The complaint, styled as an action under the Federal Tort Claims Act, contended that correctional officers failed to prevent the attack despite being aware of a prior altercation. On March 23, 2023, the district court addressed the government's motion to dismiss for lack of subject matter jurisdiction. The court analyzed whether the discretionary function exception to the FTCA applied to housing and security decisions made by prison officials. After reviewing the administrative claim record, the court found that the challenged supervisory and safety protocols fell within the protected discretionary sphere, meaning the United States retained sovereign immunity and consent to suit was lacking. The case was dismissed with prejudice.

The court granted the United States' motion to dismiss for lack of subject matter jurisdiction, holding that the challenged prison management decisions were protected by the discretionary function exception and sovereign immunity was not waived.

Whether the discretionary function exception to the Federal Tort Claims Act barred a prisoner's negligence claim against the United States arising from an assault by another inmate.

The ruling reinforced the wide latitude afforded to federal prison officials under the FTCA's discretionary function exception, limiting the ability of inmates to hold the United States liable for operational security choices. It served as a procedural barrier reminder for incarcerated litigants and underscored judicial deference to agency decision-making within custodial environments.