Swafford v. United States, No. 15-15412 (11th Cir. 2016)
Annotate this CaseSwafford traveled to the R. Shaefer Heard Campground, near West Point, Georgia, owned by the Army Corps of Engineers. Swafford, with dog leash and coffee cup in hand, went away from his campsite and descended a wooden stairway to see the lake. Swafford fell and injured himself. Swafford had paid $132 for six nights of camping. The Corps is prohibited from charging “entrance or admission fees” to its recreational areas, 16 U.S.C. 460d-3(a); the fee was for use of the overnight camping facilities--a recreational-vehicle parking pad with electrical, water, and sewage services. No general, day-use access to the Campground is available; only campers and campers’ visitors (paying a "user fee") may enter. The Corps contracts with Anderson for ‘maintenance, repair, and operations of facilities, vehicles, and equipment at West Point Lake. Swafford filed a claim with the General Services Administration and received notification that investigation of his claim was complete. When Swafford did not receive a decision letter, he filed suit. The district court rejected his claim, finding that the United States was insulated from liability under both the discretionary-function exception to the Federal Tort Claims Act and the limited-liability provisions of Georgia’s Recreational Property Act. The Eleventh Circuit reversed the application of the discretionary-function exception, but affirmed the judgment because Georgia law precludes recovery against the government under the circumstances.
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