Edwin J. Blair v. Internal Revenue Service Department of the Treasury United States of America James Freitas Thomas Whatley

304 F.3d 861, 2002 Cal. Daily Op. Serv. 8228, 2002 Daily Journal DAR 10409, 90 A.F.T.R.2d (RIA) 6440, 2002 U.S. App. LEXIS 18448, 2002 WL 31014715
CourtCourt of Appeals for the Ninth Circuit
DecidedSeptember 9, 2002
Docket00-16010
StatusPublished
Cited by54 cases

This text of 304 F.3d 861 (Edwin J. Blair v. Internal Revenue Service Department of the Treasury United States of America James Freitas Thomas Whatley) is published on Counsel Stack Legal Research, covering Court of Appeals for the Ninth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Edwin J. Blair v. Internal Revenue Service Department of the Treasury United States of America James Freitas Thomas Whatley, 304 F.3d 861, 2002 Cal. Daily Op. Serv. 8228, 2002 Daily Journal DAR 10409, 90 A.F.T.R.2d (RIA) 6440, 2002 U.S. App. LEXIS 18448, 2002 WL 31014715 (9th Cir. 2002).

Opinion

OPINION

HUG, Circuit Judge.

This appeal involves a claim brought by Edwin Blair under the Federal Tort Claims Act (“FTCA”), 28 U.S.C. §§ 2671-80, for injuries suffered from an arrest by Internal Revenue Service (“IRS”) agents. The district court dismissed the claim for lack of subject matter jurisdiction because Blair had failed to present an adequate claim to the IRS prior to instituting suit as required by 28 U.S.C. § 2675(a). The court held that the claim was deficient because it failed to provide a sum certain in damages. Specifically, Blair’s submission made a claim for a sum certain for wage loss resulting from the injury, but also provided that medical expenses were still being incurred and did not provide a sum certain for medical expenses. The issue in this case is the adequacy of the claim form to provide jurisdiction under the FTCA. We hold that the district court had jurisdiction to adjudicate the wage loss claim, for which a sum certain was provided, though it did not have jurisdiction to adjudicate the medical expenses claim for which no sum certain was provided. We affirm in part, reverse in part, and remand *863 for further proceedings consistent with our opinion.

I.

Factual & Procedural History

Edwin Blair was arrested by IRS agents on April 15, 1996 for interfering with the seizure of his property. Following his arrest, Blair was handcuffed and transported by car to the United States Courthouse in downtown Sacramento. Blair alleges that he suffered significant injuries during the 45 minute car trip, primarily due to the tightness of the handcuffs on his wrists. As a result of these injuries, Blair claims that he has had to endure multiple surgeries to regain the normal use of his hands, and that he is no longer able to perform his work as a self-employed tree harvester.

Exactly two years after his arrest, Blair filed a claim with the IRS seeking compensation for his injuries. Blair filed his claim on a Standard Form 95 (“Form 95”), to which he attached several pages setting forth the details of his claim. This submission was uncontroversial in all respects but one. The Form 95 gives a claimant the opportunity to provide, among other things, various dollar amounts related to the claim. Specifically, the Form 95 lists four boxes in which a claimant may enter a dollar amount — one each for property damage, personal injury, wrongful death, and the total value of the claim. A copy of the Form 95 as submitted by Blair is attached as Appendix A. In completing his Form 95, Blair .did not list any dollar amounts on the actual form. See id. Rather, Blair left the boxes blank, with the exception of the personal injury box, in which he wrote “please see attached.” See id. In the documents attached to his Form 95, Blair provided the following information as to the amount of compensation he was seeking:

(1) Medical expenses are still being incurred, with no end presently in sight. Best estimates could perhaps be obtained by the IRS from the treating physicians listed in Item No. 11 above.
(2) Consequent.- lost income from claimant’s self-employment is calculated from April, 1996 through April, 2018 (@ claimant’s age 65 years). This figure is reached using the $200,000.00 net income figure for fiscal year 1995 and using a 10% annual increase factor, yielding a 20 year total, loss of $17,499,436.00.

Thus, Blair provided a definite monetary figure for lost wages and no monetary figure for medical expenses.

Shortly after. Blair filed his claim, the IRS informed him that it could not act on his request as long as the amount sought for medical expenses remained undetermined.. . Blair responded by providing the IRS with copies of existing medical records and bills. Subsequently, on September 11, 1998, the IRS denied Blair’s request for relief.

Following the IRS’ denial, Blair brought suit against the United States, the IRS, the Treasury Department, and the two IRS agents involved in his arrest. As part of this suit Blair sought relief under the FTCA, which, once a party meets certain jurisdictional requirements, generally provides a cause of action against the United States for torts committed by federal employees within the scope of their employment. See 28 U.S.C. § 1346(b). On motion of defendants, the district court dismissed the entire action. On appeal Blair challenges only dismissal of the FTCA claim.

As to Blair’s FTCA claim, the Government argued .that, on the basis of the claim presentation rule, the district court lacked subject matter jurisdiction. Under the claim presentation rule, a district court *864 cannot exercise subject matter jurisdiction over an action brought pursuant to the FTCA unless the plaintiff “shall have first presented the claim to the appropriate Federal agency....” 28 U.S.C. § 2675(a). A claim is deemed presented for purposes of § 2675(a) when a party files “(1) a written statement sufficiently describing the injury to enable the agency to begin its own investigation, and (2) a sum certain damages claim.” Warren v. United States Dep’t of Interior Bureau of Land Mgmt., 724 F.2d 776, 780(9th Cir.1984) (en banc).

The Government contended that Blau-failed to comply with the claim presentation rule by failing to state a sum certain for his entire claim, and thus, that there was no adequate presentation of the claim and no subject matter jurisdiction. The district court granted the Government’s motion to dismiss the FTCA claim for lack of subject matter jurisdiction because of the failure to present an adequate claim to the federal agency. Following the district court’s decision, Blair filed this appeal, in which he challenges the dismissal of his FTCA claim.

II.

Jurisdiction & Standard of Review

The district court had jurisdiction under 28 U.S.C. §§ 1331 and 1346(b). We have jurisdiction pursuant to 28 U.S.C. § 1291. A district court’s dismissal for lack of subject jurisdiction is reviewed de novo. See Sommatino v. United States, 255 F.3d 704, 707 (9th Cir.2001).

III.

Statutory Requirements

In 1946 Congress passed the FTCA. Under the FTCA, as enacted in 1946, government agencies had no authority to settle claims over $2500. In 1966 the FTCA was amended to revise this procedure and provide greater opportunity for settlement before suit is filed. Our en banc decision in Warren traced the legislative history and the reasons for the change.

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304 F.3d 861, 2002 Cal. Daily Op. Serv. 8228, 2002 Daily Journal DAR 10409, 90 A.F.T.R.2d (RIA) 6440, 2002 U.S. App. LEXIS 18448, 2002 WL 31014715, Counsel Stack Legal Research, https://law.counselstack.com/opinion/edwin-j-blair-v-internal-revenue-service-department-of-the-treasury-ca9-2002.