Pritchett v. United States of America

Jerry L. Pritchett, a veteran, died in 2013 allegedly due to negligent care at a Department of Veterans Affairs hospital. His widow, Earnestine Pritchett, as personal representative of his estate, sued the United States under the Federal Tort Claims Act, seeking damages for wrongful death. The United States moved to dismiss for lack of subject matter jurisdiction, arguing that the claim was barred by 38 U.S.C. § 511, which precludes judicial review of VA decisions affecting benefits. The district court agreed and dismissed the case. On November 26, 2018, the United States Court of Appeals for the Eleventh Circuit affirmed, holding that the FTCA claim could not proceed because it was inextricably intertwined with a benefits determination. The Supreme Court later denied certiorari.

The district court dismissed the case for lack of jurisdiction. The Eleventh Circuit affirmed the dismissal, and the U.S. Supreme Court denied certiorari, leaving the ruling in place.

Whether federal courts have subject matter jurisdiction over a medical malpractice claim against the Department of Veterans Affairs under the Federal Tort Claims Act when the claim requires review of a VA benefits decision, given the jurisdictional bar in 38 U.S.C. § 511.

The decision underscored significant obstacles for veterans and their families seeking compensation for VA medical negligence, reinforcing a broad interpretation of the statutory bar on judicial review. It sparked criticism from veterans' advocates who argued that the ruling denied justice to those harmed by substandard VA care, and it fueled ongoing debates about reforming the FTCA to allow such claims.