Cunningham v. General Dynamics Information Technology, Inc., No. 17-1592 (4th Cir. 2018)Annotate this Case
The Yearsley doctrine applies to claims arising under federal law. The Fourth Circuit affirmed the district court's grant of GDIT's motion to dismiss, for lack of subject matter jurisdiction, an action alleging that GDIT violated the Telephone Consumer Protection Act (TCPA). The court held that GDIT was immune from suit under the Yearsley doctrine, which immunizes government contractors from suit when the government authorized the contractor's actions and the government validly conferred that authorization. The court found nothing in Yearsley or its progeny that limited its application solely to state law liability. The court held that the district court did not err in treating Yearsley applicability as a jurisdictional bar to suit and granting GDIT's motion to dismiss.