FAWCETT v. United States

CourtDistrict Court, D. Maine
DecidedAugust 19, 2025
Docket2:24-cv-00235
StatusUnknown

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

Bluebook
FAWCETT v. United States, (D. Me. 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF MAINE

SHIRLEY FAWCETT, ) ) Plaintiff, ) ) v. ) Docket No. 2:24-cv-00235-NT ) UNITED STATES OF AMERICA, ) ) Defendant. )

ORDER ON MOTION TO DISMISS Before me is the Defendant’s motion to dismiss the Plaintiff’s amended complaint (ECF No. 12). For the reasons stated below, the motion is GRANTED IN PART and DENIED IN PART. BACKGROUND On May 3, 2023, Shirley Fawcett had an appointment with the Social Security Administration (“SSA”). 1st Am. Compl. (“Am. Compl.”) ¶¶ 32, 34 (ECF No. 7). The SSA “serves all Americans,” but “a large percentage” of its office visitors are “elderly, disabled, or both.” Am. Compl. ¶ 22. The purpose of Ms. Fawcett’s appointment was to obtain a new Social Security card, which she needed to move into a new independent living facility. Am. Compl. ¶ 32. The appointment, which had to be in- person, was at the SSA’s office in the Custom House in downtown Portland, Maine. Am. Compl. ¶¶ 5, 35–36. The SSA had just moved into the Custom House days before. Am. Compl. ¶ 35. Ms. Fawcett’s daughter called ahead of the visit, and an SSA agent told her the office was located inside the Custom House on Commercial Street. Sworn Aff. of Victoria Thayer (“Thayer Aff.”) ¶¶ 5–6 (ECF No. 34-4). The SSA agent did not tell her about any other entrances to the Custom House. Thayer Aff. ¶ 7. Ms. Fawcett’s daughter drove her to her appointment and dropped her off at

the Custom House’s back entrance on Commercial Street. Am. Compl. ¶¶ 38–39; Thayer Aff. ¶ 8. There were no signs at the Commercial Street entrance informing visitors that additional and accessible entrances were available. Thayer Aff. ¶ 9. Ms. Fawcett’s daughter would have liked to help her mother into and out of the building, but there was no available parking nearby. Am. Compl. ¶ 39; Thayer Aff. ¶ 8. So, Ms. Fawcett’s daughter circled the area and (unsuccessfully) looked for a parking spot.

Am. Compl. ¶¶ 39, 45. After Ms. Fawcett’s SSA appointment, she exited the Custom House through the back entrance on Commercial Street. Am. Compl. ¶ 42. That entrance has multiple steps between the entrance doors and the sidewalk. Decl. of Waldemar Rogowicz (“Rogowicz Decl.”) ¶ 5 (ECF No. 32); Am. Compl. ¶ 19. The entrance had no handrails. Am. Compl. ¶ 19. Ms. Fawcett could walk independently but was elderly and relied on handrails on staircases. Am. Compl. ¶ 37. Though she proceeded

as carefully as possible, it had rained that day, and the steps were slippery. Am. Compl. ¶¶ 41, 46–47. Without a handrail to help her balance, Ms. Fawcett fell down the stairs and onto the pavement below. Am. Compl. ¶¶ 46–48. She sustained significant injuries from the fall. Am. Compl. ¶ 49. The Custom House, a historically significant building listed in the National Register of Historic Places, is maintained and managed by the General Services Administration (“GSA”), a federal agency that provides workspaces for federal employees and operates federal buildings. Am. Compl. ¶¶ 4–5; Def.’s Mot. Exs. 10, 11 (ECF Nos. 12-10, 12-11). The GSA completed major projects on the Custom House in

1998, 2009, and 2013. Rogowicz Decl. ¶¶ 6–9. At some point, the GSA installed a handrail on the steps of the Custom House’s front entrance on Fore Street. Am. Compl. ¶ 15.1 In 2009, the GSA’s work included alterations to the Commercial Street entrance’s exterior door. Rogowicz Decl. ¶ 8. But the steps at the Commercial Street entrance “are original to the building and have not been altered or renovated.” Rogowicz Decl. ¶ 6. In 2013, the GSA added a handicap-accessible walkway and

entrance with an automatic door on the Custom House Street side of the building, among other accessibility upgrades. Rogowicz Decl. ¶¶ 9–10. The GSA completed this 2013 project “to provide an accessible route to meet [Architectural Barriers Act] compliance.” Rogowicz Decl. ¶ 10. In July of 2024, Ms. Fawcett filed a one-count complaint against the United States2 alleging that the GSA’s negligence caused her fall and resulting injuries. Compl. (ECF No. 1). The United States filed a motion to dismiss for lack of jurisdiction

and Ms. Fawcett responded by amending her complaint. Mot. to Dismiss (ECF No. 6); Am. Compl. Her amended complaint added allegations of negligence against the SSA,

1 Ms. Fawcett alleged that the Fore Street handrail was added in 1998, 1st Am. Compl. (“Am. Compl.”) ¶¶ 6–8, 14–15 (ECF No. 7), but jurisdictional discovery has cast doubt on that allegation, see United States’ Suppl. Briefing 4–5 (ECF No. 33). In any event, the timing of the installation of the railing at the Fore Street entrance is not relevant to the analysis that follows. 2 I use the terms “Defendant,” “United States,” and “Government” interchangeably in this order. among other changes.3 See Am. Compl. ¶¶ 22–31. The United States once again filed a motion to dismiss, and I held oral argument on the motion. Mot. to Dismiss Am. Compl. Pursuant to Fed. R. Civ. P. 12(b)(1) (“Def.’s Mot.”) (ECF No. 12); Minute

Entry (ECF No. 27). During oral argument it became clear that there were open— and, according to the parties, easily answerable—questions about key facts that bore on my jurisdiction over this dispute. Accordingly, I deferred ruling on the motion to dismiss and ordered the parties to propose a plan for limited jurisdictional discovery and supplemental briefing, which they did, and which I approved. Minute Entry; Order on Jurisdictional Discovery (ECF No. 29). With the benefit of additional

discovery and briefing, the matter is now before me on the United States’ motion to dismiss the amended complaint for lack of jurisdiction.4 LEGAL STANDARD On a motion to dismiss for lack of subject matter jurisdiction under Federal

Rule of Civil Procedure 12(b)(1), I accept as true all well-pleaded facts in the plaintiff’s complaint, evaluate them in the light most favorable to the plaintiff, and draw all reasonable inferences in the plaintiff’s favor. Fothergill v. United States, 566 F.3d

3 The Plaintiff’s amended complaint named the Social Security Administration (“SSA”) as the defendant. See Am. Compl. 1. At oral argument, Plaintiff’s counsel explained that this was a typographical error and that the United States is the proper defendant. I have modified the caption accordingly and recognize the United States as the only defendant. See Fed. R. Civ. P. 21 (“On motion or on its own, the court may at any time, on just terms, add or drop a party.”). 4 Ms. Fawcett requested another oral argument in her supplemental brief. Pl.’s Suppl. Briefing on Def.’s Mot. to Dismiss (“Pl.’s Suppl. Br.”) 13 (ECF No. 34). Based on my analysis of the parties’ supplemental filings and given that I have already held oral argument on the Government’s motion to dismiss, I do not view a second oral argument as helpful here. Accordingly, I DENY Ms. Fawcett’s request for oral argument. 248, 251 (1st Cir. 2009). I may consider evidence submitted by the parties without converting a Rule 12(b)(1) motion to dismiss into a Rule 56 motion for summary judgment. Gonzales v. United States, 284 F.3d 281, 288 (1st Cir. 2002). “As the party

asserting federal jurisdiction, [the] [P]laintiff[ ] bear[s] the burden of establishing its existence.” Reyes-Colón v. United States, 974 F.3d 56, 60 (1st Cir. 2020). DISCUSSION I. The Federal Tort Claims Act and the Discretionary Function Exception “As a sovereign, the United States is immune from suit unless it consents to being sued.” Reyes-Colón, 974 F.3d at 58. Congress has the authority to grant that consent and remove sovereign immunity. Merlonghi v.

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

Related

Gent v. CUNA Mutual Insurance Society
611 F.3d 79 (First Circuit, 2010)
Merlonghi v. United States
620 F.3d 50 (First Circuit, 2010)
Shansky v. United States
164 F.3d 688 (First Circuit, 1999)
Dynamic Image Technologies, Inc. v. United States
221 F.3d 34 (First Circuit, 2000)
Hajdusek v. United States
895 F.3d 146 (First Circuit, 2018)
Reyes-Colon v. United States
974 F.3d 56 (First Circuit, 2020)
Davallou v. United States
998 F.3d 502 (First Circuit, 2021)
Denmark v. Liberty Life Assurance Co.
566 F.3d 1 (First Circuit, 2009)
Phillip Alberty v. United States
54 F.4th 571 (Eighth Circuit, 2022)

Cite This Page — Counsel Stack

Bluebook (online)
FAWCETT v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/fawcett-v-united-states-med-2025.