Bryan Samuel v. United States of America, Q. Murphy

CourtDistrict Court, M.D. Pennsylvania
DecidedMay 19, 2026
Docket3:26-cv-00232
StatusUnknown

This text of Bryan Samuel v. United States of America, Q. Murphy (Bryan Samuel v. United States of America, Q. Murphy) is published on Counsel Stack Legal Research, covering District Court, M.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bryan Samuel v. United States of America, Q. Murphy, (M.D. Pa. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA BRYAN SAMUEL, : Civil No. 3:26-cv-232 Plaintiff (Judge Mariani) v. : UNITED STATES OF AMERICA, . Q. MURPHY, Defendants MEMORANDUM Plaintiff, Bryan Samuel (“Samuel”), an inmate confined at the United States Penitentiary at Canaan (“USP-Canaan’), Pennsylvania, commenced this Federal Tort Claims Act (“FTCA”), 28 U.S.C. § 2671, et seq. action on February 2, 2026, naming as Defendants the United States of America and Corrections Officer Q. Murphy. (Doc. 1). Samuel alleges that his personal property was negligently lost or stolen following an altercation at USP-Canaan. (/d. at 4-5). Presently pending is Defendants’ motion (Doc. 15) to dismiss pursuant to Federal Rule of Civil Procedure 12(b)(1). Samuel failed to respond to the motion and the time for responding has now passed.’ Therefore, the motion is deemed unopposed and ripe for disposition. For the reasons set forth below, the Court will grant the motion to dismiss.

1 Samuel was directed to file a brief in opposition to Defendants’ motion and was admonished that failure to file an opposition brief would result in Defendants’ motion being deemed unopposed. (Doc. 19) (citing M.D. PA. LOCAL RULE OF CouRT 7.6).

l. Background Samuel alleges that on February 23, 2025, he was involved in a fight with several inmates in Unit D-1 at USP-Canaan. (Doc. 1, at 4). He asserts that staff members broke up the fight, the Unit was secured, and Samuel was escorted to the Lieutenant's office. (/d.). Samuel contends that Corrections Officer Q. Murphy was the reporting and investigating officer, and that it was his duty to follow procedures for handling inmate personal property. (Id. at5). Samuel alleges that Defendant Murphy “fail[ed] to do this” and “breached his duty.” (/d.). He further alleges that, in breaching his duty, Defendant Murphy caused Samuel's personal property to be “lost, stolen or otherwise disappeared.” (/d.). For relief, Samuel seeks $5,000 in damages. (Id.). Defendants now move to dismiss the complaint for lack of subject matter jurisdiction. (Docs. 15, 18). Specifically, Defendants argue that Murphy is not a proper Deferidant in an FTCA action, and the loss of property claim, alleged to have been committed negligently or wrongfully by a federal corrections officer (who is a law enforcement officer), is barred by sovereign immunity under the FTCA. (Doc. 18). Il. Legal Standard Federal Rule of Civil Procedure 12(b)(1) authorizes a court to dismiss an action for lack of subject matter jurisdiction. Feb. R. Civ... 12(b)(1). Motions brought uider Rule 122(b)(1) may present either a facial or factual challenge to the court's subject matter jurisdiction. Gould Elecs., Inc. v. United States, 220 F.3d 169, 176 (3d Cir. 2000). In

reviewing a facial challenge under Rule 12(b)(1), the standards associated with Rule 12(b)(6) are applicable. See id. In this regard, the court must accept all factual allegations in the complaint as true, and the court may consider only the complaint and documents referenced in or attached to the complaint. In a factual challenge to the court's subject matter jurisdiction, the court’s analysis is not limited to the allegations of the complaint, and the presumption of truthfulness does not attach to the allegations. Mortensen v. First Fed. Sav, & Loan Ass'n, 549 F.2d 884, 891 (3d Cir. 1977). Instead, the court may consider evidence outside the pleadings, including affidavits, depositions, and testimony, to resolve

any factual issues bearing on jurisdiction. Gotha v. United States, 115 F.3d 176, 179 (3d Cir. 1997). Once the court’s subject matter jurisdiction over a complaint is challenged, the plaintiff bears the burden of proving that jurisdiction exists. Mortensen, 549 F.2d at 891. If a dispute of material fact exists, “the court must conduct a plenary hearing on the contested issues prior to determining jurisdiction.” McCann v. Newman Irrevocable Tr., 458 F.3d 281, 290 (3d Cir. 2006); see also Berardi v. Swanson Mem’! Lodge No. 48, 920 F.2d 198, 200 (3d Cir. 1990) (stating that a district court must ensure that a plaintiff has “had an opportunity to present facts by affidavit or by deposition, or in an evidentiary hearing,” to support his claim of jurisdiction (citation omitted)).

lll. Discussion A. Defendant Murphy The FTCA, 28 U.S.C. § 2679(b)(1), provides that a suit against the United States is

the exclusive remedy for persons seeking recovery for common law torts committed by federal employees within the scope of their federal employment. See also 28 U.S.C. § 1346(b) (governing jurisdiction). Because the FTCA is a limited waiver of sovereign immunity which extends to the United States, but not to its agencies and employees, the United States is the only appropriate Defendant. See CNA v. United States, 535 F. 3d 132, 138 n.2 (3d Cir. 2008) (“The Government is the only proper defendant in a case brought under the FTCA.”): Feaster v. Federal Bureau of Prisons, 366 F. App’x 322, 323 (3d Cir. 2010) (“The only proper defendant in an FTCA suit is the United States itself.”). As such, Defendant Murphy is entitled to dismissal on this ground. B. Detention of Goods Exception The FTCA is a limited waiver of sovereign immunity, which may permit the United States to be sued for “injury or death caused by the negligent or wrongful act or omisision of [an employee] of the Government while acting within the scope of his office or employment.” 28 U.S.C. § 1346(b); Ali v. Federa’ Bureau of Prisons, 552 U.S. 214, 217-18 (2008). Defendants argue that Samuel's property loss claims are not cognizable under the FTCA because they fall within the “detention of goods exception” to the Act's waiver of sovereign immunity. (Doc. 18, at 6-9). This exception is set forth at 28 U.S.C. § 2680(c)

and provides that the government’s waiver of immunity under the FTCA “shall not apply to...[a]ny claim arising in respect of the assessment or collection of any tax or customs duty, or the detention of any goods, merchandise, or other property by any officer of customs or excise or any other law enforcement officer...” 28 U.S.C. § 2680(c) (emphasis added). Here, Samuel alleges that his personal property was negligently handled at USP- Canaan by Defendant Murphy, a Bureau of Prisons (“BOP”) Corrections Officer. (See Doc. 1 at 2, identifying Q. Murphy as a Corrections Officer at USP-Canaan). Such handling of Samuel's property plainly constitutes a “detention of goods” within the meaning of 28 U.S.C. § 2680(c). See Kosak v. United States, 465 U.S. 848

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Kosak v. United States
465 U.S. 848 (Supreme Court, 1984)
Ali v. Federal Bureau of Prisons
552 U.S. 214 (Supreme Court, 2008)
Sheila Gotha v. United States
115 F.3d 176 (Third Circuit, 1997)
Cna v. United States
535 F.3d 132 (Third Circuit, 2008)
Gordon v. United States
279 F. App'x 126 (Third Circuit, 2008)
Gibson v. Sadowski
308 F. App'x 580 (Third Circuit, 2009)
Feaster v. Federal Bureau of Prisons
366 F. App'x 322 (Third Circuit, 2010)

Cite This Page — Counsel Stack

Bluebook (online)
Bryan Samuel v. United States of America, Q. Murphy, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bryan-samuel-v-united-states-of-america-q-murphy-pamd-2026.