Dulce Santos v. United States of America

CourtDistrict Court, S.D. New York
DecidedFebruary 19, 2026
Docket1:24-cv-09887
StatusUnknown

This text of Dulce Santos v. United States of America (Dulce Santos v. United States of America) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Dulce Santos v. United States of America, (S.D.N.Y. 2026).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK -----------------------------------------------------------------X

DULCE SANTOS, 24-CV-9887 (VF) Plaintiff, OPINION & ORDER -against-

UNITED STATES OF AMERICA,

Defendant.

-----------------------------------------------------------------X

VALERIE FIGUEREDO, United States Magistrate Judge. Plaintiff Dulce Santos (“Plaintiff”) commenced this action on December 23, 2024, against the United States of America (the “Government”), asserting a claim for negligence pursuant to the Federal Tort Claims Act (“FTCA”) under 28 U.S.C. § 1346(b) for failing to properly maintain a sidewalk on which Plaintiff fell on December 26, 2021. ECF No. 1. Pending before the Court is the Government’s motion to dismiss Plaintiff’s complaint under Federal Rule of Civil Procedure 12(b)(1) for lack of subject-matter jurisdiction. For the reasons set forth below, the Government’s motion is GRANTED and Plaintiff’s complaint is dismissed without prejudice. FACTUAL AND PROCEDURAL BACKGROUND On December 26, 2021, Plaintiff tripped and fell on a “raised,” “broken,” or “missing” portion of a sidewalk (ECF No. 1 at ¶¶ 10-12) that was appurtenant to “a United States Federal Office Building located at 1771 Andrews Avenue” in the Bronx (id. at ¶ 2). As a result of the fall, Plaintiff “sustained serious injuries in her shoulder.” Id. at ¶ 34. On December 19, 2023, Plaintiff “submitted an administrative claim for her December 26, 2021 injury” to the United States Department of Justice, Federal Torts Claim Act Section. Id. at ¶ 5. To date, the Government has not issued a denial of Plaintiff’s administrative claim. Id. at ¶ 6. Plaintiff filed this lawsuit on December 23, 2024, alleging that the Government and/or its “agents” failed to properly maintain the sidewalk, thereby causing the unsafe condition that led to Plaintiff’s fall. Id. at ¶¶ 15, 22-23, 26-28. Plaintiff further alleges that the Government had

actual or constructive notice of the defective condition on the sidewalk but failed to repair the condition. Id. at ¶¶ 24-25, 29-30. The Government moved to dismiss the complaint on June 30, 2025, for lack of subject- matter jurisdiction pursuant to Federal Rule of Civil Procedure 12(b)(1). ECF No. 27. Plaintiff opposed the Government’s motion on August 5, 2025. ECF No. 32. The Government filed a reply in support of its motion on August 15, 2025. ECF No. 35. LEGAL STANDARD A. Subject-Matter Jurisdiction “‘Determining the existence of subject matter jurisdiction is a threshold inquiry and a

claim is properly dismissed for lack of subject matter jurisdiction under Rule 12(b)(1) when the district court lacks the statutory or constitutional power to adjudicate it.’” Morrison v. Nat’l Austl. Bank Ltd., 547 F.3d 167, 170 (2d Cir. 2008). “A plaintiff asserting subject matter jurisdiction has the burden of proving by a preponderance of the evidence that it exists.” Makarova v. United States, 201 F.3d 110, 113 (2d Cir. 2000) (citation omitted). While the Court must accept as true all factual allegations in the complaint, Morrison, 547 F.3d at 170 (citation omitted), the Court may not draw any jurisdictional inferences in favor of the plaintiff. Fraser v. United States, 490 F. Supp. 2d 302, 307 (E.D.N.Y. 2007) (citing Shipping Fin. Servs. Corp. v. Drakos, 140 F.3d 129, 131 (2d Cir. 1998)). “Jurisdiction must be shown affirmatively, and that

2 showing is not made by drawing from the pleadings inferences favorable to the party asserting it.” APWU v. Potter, 343 F.3d 619, 623 (2d Cir. 2003) (internal quotation marks and citation omitted). Thus, in resolving a motion to dismiss for lack of subject-matter jurisdiction under Rule 12(b)(1), a district court may consider evidence outside the pleadings. Morrison, 547 F.3d at 170. Such evidence outside the pleadings includes “sworn affidavits, correspondence between

the parties, contracts, or other relevant documents[.]” King Cnty., Wash. v. IKB Deutsche Industriebank AG, 712 F. Supp. 2d 104, 112 (S.D.N.Y. 2010). “The consideration of materials extrinsic to the pleadings does not convert the Rule 12(b)(1) motion into one for summary judgment.” Bentley v. Wellpoint Co., Inc., No. 11-CV-8963 (CM), 2012 WL 546991, at *2 (S.D.N.Y. Feb. 17, 2012) (internal alteration and citation omitted). B. The Federal Torts Claims Act The FTCA establishes that “[t]he United States, as sovereign, is immune from suit save as it consents to be sued . . . , and the terms of its consent to be sued in any court define that court’s jurisdiction to entertain the suit.” Makarova, 201 F.3d at 113 (quoting United States v.

Mitchell, 445 U.S. 535, 538 (1980)) (alterations in original). Because “[t]he doctrine of sovereign immunity is jurisdictional in nature . . . to prevail, the plaintiff bears the burden of establishing that her claims fall within an applicable waiver.” Id. (internal quotation marks and citations omitted). Additionally, “[b]ecause the FTCA creates a waiver of sovereign immunity, it is strictly construed and all ambiguities are resolved in favor of the United States.” Fraser, 490 F. Supp. 2d at 308 (citation omitted). The FTCA provides a limited waiver of the Government’s sovereign immunity for claims “for injury or loss of property, or personal injury or death caused by the negligence or wrongful act or omission of any employee of the [G]overnment while acting within the scope of his office

3 or employment.” 28 U.S.C. § 1346(b); see also Leone v. United States, 910 F.2d 46, 48-49 (2d Cir. 1990). For the Government to be liable under the FTCA, a federal employee must be found to be both negligent and acting within the scope of his duties. See 28 U.S.C. § 1346(b); see also Squicciarini v. United States, No. 12-CV-2386 (ER), 2013 WL 620190, at *3 (S.D.N.Y. Feb. 15, 2013). The FTCA defines government “employees” as any “officers or employees of any federal

agency, . . . and persons acting on behalf of a federal agency in an official capacity.” 28 U.S.C. § 2671. The definition of “employee of the Government” specifically excludes “any contractor with the United States.” 28 U.S.C. § 2671. “Thus, as a general rule, sovereign immunity precludes suits against the United States for injuries caused by its independent contractors.” Roditis v. United States, 122 F.3d 108, 111 (2d Cir. 1997) (per curiam); see also Carter v. United States, No. 96-CV-9139 (MBM), 1998 WL 744009, at *2 (S.D.N.Y. Oct.

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