Soto-Cintron v. United States, No. 17-1180 (1st Cir. 2018)Annotate this Case
The First Circuit affirmed the district court’s grant of summary judgment in favor of the government on Plaintiff’s claim under the Federal Tort Claims Act (FTCA) for false imprisonment, holding that while the decision of agents from the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) to prevent Plaintiff and his son from leaving a Puerto Rico post office parking lot was wrong, that decision was reasonable and did not expose the United States to liability.
After Plaintiff’s son retrieved some envelopes from the post office Plaintiff and his son began pulling out of the parking lot but were stopped by ATF agents with guns drawn. Plaintiff was removed from the vehicle and handcuffed, and Plaintiff and his son were detained for approximately twenty minutes. ATF agents released Plaintiff and his son when they realized they had stopped the wrong people in searching for the person who had received an illegal shipment of firearms. Based on this incident, Plaintiff filed his complaint. The district court granted the government’s motion for summary judgment. The First Circuit affirmed, holding that even if the agents did not have probable cause to arrest, Puerto Rico would not impose liability for false imprisonment, and, given the vicarious liability premise of the FTCA, the United States was not exposed to liability.