GARRIS v. United States

CourtDistrict Court, W.D. Pennsylvania
DecidedJuly 2, 2025
Docket2:24-cv-00483
StatusUnknown

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

Bluebook
GARRIS v. United States, (W.D. Pa. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA MICHAEL GARRIS, LORILYNN GARRIS,

2:24-CV-00483-CCW Plaintiffs,

v.

UNITED STATES OF AMERICA,

Defendant.

OPINION Before the Court is the United States’ Motion to Dismiss Plaintiffs Michael Garris and Lorilynn Garris’s Complaint pursuant to Rule 12(b)(1) of the Federal Rules of Civil Procedure. ECF No. 16. For the reasons set forth below, the Court will grant the United States’ Motion. I. Background

Mr. Garris worked as a driver for a company that contracted with the United States Postal Service to haul mail between USPS facilities. ECF No. 17 at 1. On January 6, 2022, Mr. Garris “was loading cages onto the dock” at the Greensburg, Pennsylvania post office when “the dock lift broke causing [him] to fall and sustain serious injuries.” ECF No. 1 ¶¶ 8–9. Mr. Garris alleges that the USPS was negligent in maintaining the dock lift, resulting in its failure. Id. ¶¶ 10–11. Accordingly, Mr. Garris asserts a negligence claim against the United States. Id. ¶¶ 12–14. His wife, Ms. Garris, brings a loss of consortium claim against the United States for the same allegedly negligent conduct. Id. ¶¶ 15–16. The Garrises allege that the Court has subject matter jurisdiction under the Federal Tort Claims Act, 28 U.S.C. § 2671, et seq. (“FTCA”) pursuant to 28 U.S.C. § 1346(b)(1). See ECF No. 1 ¶ 1. The United States has moved to dismiss the Complaint pursuant to Rule 12(b)(1) of the Federal Rules of Civil Procedure. ECF No. 16. The Motion is fully briefed and ripe for resolution. ECF Nos. 17, 25, 29. II. Legal Standard

“A challenge to subject matter jurisdiction under Rule 12(b)(1) may be either a facial or a factual attack.” Davis v. Wells Fargo, 824 F.3d 333, 346 (3d Cir. 2016). A facial challenge contests subject matter jurisdiction without contesting the facts alleged in the complaint, whereas a factual challenge “attacks the factual allegations underlying the complaint’s assertion of jurisdiction, either through the filing of an answer or ‘otherwise present[ing] competing facts.’” Id. (quoting Constitution Party of Pa. v. Aichele, 757 F.3d 347, 358 (3d Cir. 2014)). “In sum, a facial attack ‘contests the sufficiency of the pleadings’ . . . ‘whereas a factual attack concerns the actual failure of a [plaintiff’s] claims to comport [factually] with the jurisdictional prerequisites.’” Constitution Party, 757 F.3d at 358 (citations omitted). Here, the United States presents a factual challenge to subject matter jurisdiction because

it introduces information from outside the pleadings to argue that the USPS qualifies as a “statutory employer” under Pennsylvania law and is therefore immune from liability, and this immunity divests the Court of subject matter jurisdiction. See ECF No. 17. As such, in ruling on the United States’ Motion, the Court “does not attach a presumption of truthfulness to the plaintiff’s allegations” and “must weigh the evidence relating to jurisdiction, [including] affidavits, documents, and even limited evidentiary hearings to make the jurisdictional determination.” McCluskey v. United States, No. CIV.A. 10-694, 2010 WL 4024717, at *3 (W.D. Pa. Oct. 12, 2010) (Fischer, J.) (citing Atkinson v. Pa. Shipbuilding Co., 473 F.3d 506, 514 (3d Cir.2007)). III. Legal Analysis

“It is axiomatic that the United States may not be sued without its consent and that the existence of consent is a prerequisite for jurisdiction.” United States v. Mitchell, 463 U.S. 206, 212 (1983). “Absent a waiver, sovereign immunity shields the Federal Government and its agencies from suit.” F.D.I.C. v. Meyer, 510 U.S. 471, 475 (1994). “A plaintiff attempting to sue any government agency . . . ‘must identify a specific statutory provision that waives the government’s sovereign immunity.’” Manns v. Bureau of Prisons, No. 05-cv-315, 2006 WL 3813926, at *2 (W.D. Pa. Dec. 26, 2006) (McLaughlin, J.) (quoting Clinton Cnty. Commr’s v. U.S. E.P.A., 116 F.3d 1018, 1021 (3d Cir. 1997)); see also Bah v. United States, 91 F.4th 116, 120 (3d Cir. 2024) (“Because sovereign immunity is jurisdictional in nature, the terms of [the government’s] consent to be sued in any court define that court’s jurisdiction to entertain the suit.”) (cleaned up). Here, the Garrises bring their claims against the United States pursuant to the FTCA. ECF

No. 1 ¶ 1. “Under the FTCA, the federal government only waives its immunity for injuries ‘caused by the negligent or wrongful act or omission of any employee of the Government . . . under circumstances where the United States, if a private person, would be liable to the claimant in accordance with the law of the place where the act or omission occurred.’” In re Orthopedic Bone Screw Prod. Liab. Litig., 264 F.3d 344, 361–62 (3d Cir. 2001), as amended (Oct. 10, 2001) (quoting 28 U.S.C. § 1346(b)(1)). “Thus, the extent of the United States’ liability under the FTCA is generally determined by reference to state law.” Id. at 362. “When interpreting state law, [the Court] follow[s] a state’s highest court; if that state’s highest court has not provided guidance, [the Court is] charged with predicting how that court would resolve the issue.” In re Energy Future Holdings Corp., 842 F.3d 247, 253–54 (3d Cir. 2016); see also Nationwide Mut. Ins. Co. v. Buffetta, 230 F.3d 634, 637 (3d Cir. 2000) (stating that the district court properly tried to predict how the Pennsylvania Supreme Court would rule on an issue of Pennsylvania state law “[b]ecause there was no reported decision by the Pennsylvania Supreme Court or any other Pennsylvania court addressing the precise issue before it”). Importantly, in an FTCA case “a plaintiff must

plausibly allege that ‘the United States, if a private person, would be liable to the claimant’ under state law both to survive a merits determination under Rule 12(b)(6) and to establish subject-matter jurisdiction.” Brownback v. King, 592 U.S. 209, 218 (2021) (quoting 285 U.S.C. § 1346(b)(1)). Here, all parties agree that Pennsylvania law governs the Garrises’ claims because Mr. Garris was allegedly injured on the loading dock at the USPS’s Greensburg, Pennsylvania post office. See ECF No. 1 ¶¶ 8–9; ECF No. 17 at 5; ECF No. 25 at 3. For the below reasons, the Court concludes that the Unites States is immune from suit under Pennsylvania law. Accordingly, the Court lacks subject matter jurisdiction and will dismiss this case without prejudice. A.

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Related

United States v. Mitchell
463 U.S. 206 (Supreme Court, 1983)
Federal Deposit Insurance v. Meyer
510 U.S. 471 (Supreme Court, 1994)
Nationwide Mut. Ins. Co. v. Buffetta
230 F.3d 634 (Third Circuit, 2000)
Fonner v. Shandon, Inc.
724 A.2d 903 (Supreme Court of Pennsylvania, 1999)
Barchfeld v. Nunley by Nunley
577 A.2d 910 (Supreme Court of Pennsylvania, 1990)
Six L'S Packing Co. v. Workers' Compensation Appeal Board
44 A.3d 1148 (Supreme Court of Pennsylvania, 2012)
Constitution Party of Pennsylv v. Carol Aichele
757 F.3d 347 (Third Circuit, 2014)
Onyiuke v. New Jersey State Supreme Court
242 F. App'x 794 (Third Circuit, 2007)
Maria Garlick v. Trans Tech Logistics Inc
636 F. App'x 108 (Third Circuit, 2015)
Doman v. Atlas America, Inc.
150 A.3d 103 (Superior Court of Pennsylvania, 2016)
Brownback v. King
592 U.S. 209 (Supreme Court, 2021)
Davis v. Wells Fargo, U.S.
824 F.3d 333 (Third Circuit, 2016)
Abdoulai Bah v. United States
91 F.4th 116 (Third Circuit, 2024)

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GARRIS v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/garris-v-united-states-pawd-2025.