Watson v. United States, No. 16-655 (2d Cir. 2017)Annotate this Case
Plaintiff filed suit under the Federal Tort Claims Act (FTCA) after he was held in immigration detention for more than three years because the government mistakenly believed that he was a deportable alien. The district court found the government liable to plaintiff on the false imprisonment claim, dismissed the malicious prosecution claim and negligent investigation claim on motion, and entered judgment for the government on the negligent delay claim post-trial. The Second Circuit reversed the judgment as to the false imprisonment claim because it was time-barred. The court affirmed the judgment in all other respects, holding that the malicious prosecution claim failed because the government did not act with malice, the negligent investigation claim failed for lack of a private analogue, and the negligent delay claim failed because plaintiff suffered no cognizable damages.