Edison v. United States, No. 14-15472 (9th Cir. 2016)
Annotate this CasePlaintiffs, two prisoners housed at Taft Correction Institute, filed suit under the Federal Tort Claims Act (FTCA), 28 U.S.C. 1346, after they contracted coccidioidomycosis (cocci), alleging that the United States breached its duty to protect them from harm. Taft is the only federally-owned and contractor-operated prison in the country. The district court granted the government’s motions to dismiss for lack of subject-matter jurisdiction, Fed. R. Civ. P. 12(b)(1), under the independent contractor exception to the FTCA. The court concluded that plaintiffs have met their burden to show that the independent contractor exception does not bar the district court’s subject matter jurisdiction under the FTCA. The government owed a duty of care to plaintiffs under California law, which generally assumes that landowners have a duty to exercise reasonable care in the ownership and management of property. In this case, the government’s duty was underscored by the special relationship that California recognizes between jailer and prisoner. The court concluded that the BOP’s duty to warn prisoners before transferring them to Taft arose outside of the scope of its contractor relationship with GEO/MTC, and therefore is not barred by the independent contractor exception. Furthermore, the BOP did not delegate all of its duties to GEO/MTC, even once prisoners arrived at Taft. Instead, it retained both the exclusive right to construct new buildings and the exclusive right to make modifications to existing buildings. The BOP also explicitly excluded its contractors from participating in the development of a cocci prevention policy. As to these claims, the independent contractor exception to the FTCA does not bar the district court’s exercise of subject matter jurisdiction. Accordingly, the court reversed and remanded.
Court Description: Federal Tort Claims Act. The panel reversed the district court’s dismissal of plaintiffs’ Federal Tort Claims Act (“FTCA”) action, and held that the independent contractor exception to the FTCA did not bar plaintiffs’ claims alleging a breach of the government’s duties to prisoners housed at Taft Correctional Institution in California’s San Joaquin Valley. EDISON V. UNITED STATES 3 Plaintiffs are two prisoners housed at Taft who contracted coccidiodomycosis (“cocci”), colloquially known as “Valley Fever,” while incarcerated at Taft. Although the federal Bureau of Prisons (“Bureau”) owns Taft, independent contractors operate the prison. The panel held that plaintiffs met their burden to show that the independent contractor exception did not bar the district court’s subject matter jurisdiction under the FTCA. Specifically, the panel held that the federal government owed a duty of care to plaintiffs under California law, which generally assumes that landowners have a duty to exercise reasonable care in the ownership and management of the property. The panel further held that the government’s duty was underscored by the special relationship that California recognizes between jailer and prisoner. Concerning plaintiffs’ specific claims, first, the panel held that the Bureau’s duty to warn prisoners before transferring them to Taft arose out of the scope of its contractor relationship with the prison operators, and therefore was not barred by the independent contractor exception. The panel held that because cocci posed a hidden danger that plaintiffs could not reasonably ascertain on their own, the United States had a duty to warn plaintiffs of cocci’s risks prior to their transfer to Taft. The panel further held that the United States could not have designated this duty to the prison operators. Second, the panel held that to the extent that plaintiffs alleged that the Bureau was negligent in failing to construct covered walkways or other protective structures, the independent contractor exception to the FTCA did not bar the district court from considering their claim where the Bureau retained the duty to construct such structures. 4 EDISON V. UNITED STATES Third, the panel held that the independent contractor exception to the FTCA did not bar the district court from exercising jurisdiction over plaintiffs’ claim that the Bureau had a duty to develop an adequate cocci prevention policy where the Bureau expressed its intent to retain control over the specific duty to develop a policy for the prevention and treatment of cocci.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.