Estate of Anthony Lezurro Miller v. United States of America et al.

On March 31, 2026, Anthony Lezurro Miller, a 28-year-old African American man, was fatally shot by FBI special agents during the execution of a search warrant at his residence in Washington, D.C. The agents allegedly used a no-knock entry and opened fire within seconds, claiming Miller reached for a weapon; family members and witnesses contend he was unarmed and compliant. His estate, represented by his mother Monique Miller, filed suit against the United States and unnamed agents, asserting claims of excessive force under Bivens v. Six Unknown Named Agents and negligence under the Federal Tort Claims Act. The complaint highlights systemic failures in training and supervision. The case has drawn national attention to federal law enforcement tactics and the lack of transparency in agent-involved shootings.

The case was filed in the U.S. District Court for the District of Columbia in April 2026. As of June 2026, the government has moved to dismiss the Bivens claims, arguing that the Supreme Court’s decision in Egbert v. Boule bars such claims in this context. The motion remains pending, and no trial date has been set. The estate has sought expedited discovery to identify the involved agents.

1) Whether the FBI agents’ use of deadly force was objectively reasonable under the Fourth Amendment; 2) Whether the agents are entitled to qualified immunity; 3) Whether the United States waived sovereign immunity under the Federal Tort Claims Act for alleged negligent training, and whether the discretionary function exception applies.

The Miller shooting has galvanized civil rights organizations, leading to protests outside FBI headquarters. It has intensified legislative proposals to end qualified immunity for federal officers and to mandate body-worn cameras for all federal tactical teams. The case is being closely watched as a test of the post-Egbert viability of Bivens remedies in wrongful death actions against federal agents.