ALI v. FEDERAL BUREAU OF PRISONS
Supreme Court Cases
552 U.S. 214 (2008)
Case Overview
Legal Principle at Issue
Is the phrase "other law enforcement officer" limited to officers acting in a tax, excise, or customs capacity under the Federal Tort Claims Act?
Action
Affirmed (includes modified). Petitioning party did not receive a favorable disposition.
Facts/Syllabus
Petitioner Abdus-Shahid M.S. Ali was a federal prisoner at the U.S. Penitentiary in Atlanta, Georgia, from 2001 to 2003. In December 2003, Ali was scheduled to be transferred to the U.S. Penitentiary Big Sandy in Inez, Kentucky. Before being transferred, he left two duffle bags containing his personal property in the Atlanta prison's Receiving and Discharge Unit to be inventoried, packaged, and shipped to Big Sandy. Petitioner Ali was transferred, and his bags arrived some days later. Upon inspecting his property, he noticed that several items were missing. The staff at Big Sandy's Receiving and Discharge Unit told him that he had been given everything that was sent, and that if things were missing he could file a claim. Many of the purportedly missing items were of religious and nostalgic significance, including two copies of the Qur'an, a prayer rug, and religious magazines. Petitioner estimated that the items were worth $177.
Ali filed an administrative tort claim. In denying relief, the agency noted that, by his signature on the receipt form, petitioner had certified the accuracy of the inventory listed thereon and had thereby relinquished any future claims relating to missing or damaged property. Ali then filed a complaint alleging violations of the Federal Tort Claims Act, but the Bureau of Prisons maintained his claim was barred by the exception for property claims against law enforcement officers. The District Court agreed and dismissed Ali's claim under the Federal Tort Claims Act for lack of subject-matter jurisdiction.
Petitioner Ali appealed. The U.S. Court of Appeals for the Eleventh Circuit affirmed the district court ruling. In rejecting Ali's arguments, the Eleventh Circuit relied on the Supreme Court's broad interpretation of the "detention" clause in Kosak v. United States (1984), as well as on decisions by other federael appeals courts. The Supreme Court granted certiorari to resolve the disagreement among the appeals courts as to the scope of the law.