Pritchett v. United States

CourtDistrict Court, D. Oregon
DecidedMay 22, 2025
Docket6:24-cv-02026
StatusUnknown

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

Bluebook
Pritchett v. United States, (D. Or. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF OREGON

EUGENE DIVISION

LESLIE PRITCHETT, Civ. No. 6:24-cv-02026-AA

Plaintiff, OPINION & ORDER

vs.

UNITED STATES OF AMERICA,

Defendant. _______________________________________

AIKEN, District Judge: Self-represented Plaintiff Leslie Pritchett brings a wrongful death claim against Defendant United States of America on behalf of the U.S. Forest Service under the Federal Torts Claims Act, 28 U.S.C. §§ 1346(b), 2671 et seq. See ECF No. 1. Defendant moves to dismiss the claim for lack of subject matter jurisdiction under Rule 12(b)(1). ECF No. 6. For the reasons stated below, Defendant’s Motion, ECF No. 6, is GRANTED. Plaintiff’s claim is DISMISSED with prejudice. BACKGROUND Plaintiff alleges that her son, Maximillian Zelaya, died on August 23, 2022, when he “w[as] standing in the shallow section of the [Deschutes] River above Dillon Falls[]” in Bend, Oregon and “was taken by the current[,]” went over the falls, struck his forehead, and drowned. Standard Form 95 (“SF-95”), ECF No. 1-1 at 1. On August 22, 2024, Plaintiff initiated a wrongful death action against the U.S. Forest Service by filing SF-95 in Deschutes County Circuit Court. Id. at 1, 5. The Deschutes County Circuit Court construed the filing as a complaint and assigned

Case No. 24CV40539 to Plaintiff’s action. Id. at 5. On October 28, 2024, the court notified Plaintiff that she had not served the named defendant, U.S. Forest Service. Id. On November 5, 2024, Plaintiff served the U.S. Forest Service, which then received the SF-95. Id. at 6. On December 5, 2024, the United States, on behalf of the U.S. Forest Service, removed the action to federal court. ECF No. 1. On December 5, 2024, the United States substituted itself as Defendant. ECF No. 2.

LEGAL STANDARD Under Rule 12(b)(1), a court must dismiss claims over which the court lacks subject matter jurisdiction. Fed. R. Civ. P. 12(b)(1). “[T]he issue of federal court jurisdiction under [the Federal Torts Claims Act] does not arise until after removal to district court, for only there does the action become one against the United States.” Staple v. United States, 740 F.2d 768 (9th Cir. 1984). When subject matter

jurisdiction is challenged, the party asserting jurisdiction has the burden of establishing that it exists. Kingman Reef Atoll Invs., LLC v. United States, 541 F.3d 1189, 1197 (9th Cir. 2008). “A Rule 12(b)(1) jurisdictional attack may be facial or factual.” Safe Air for Everyone v. Meyer, 373 F.3d 1035, 1039 (9th Cir. 2004). “In a facial attack, the challenger asserts that the allegations contained in a complaint are insufficient on their face to invoke federal jurisdiction.” Id. “By contrast, in a factual attack, the challenger disputes the truth of the allegations that, by themselves, would otherwise invoke federal jurisdiction.” Id. “In resolving a factual attack on jurisdiction, the district court may review evidence beyond the complaint without converting the

motion to dismiss into a motion for summary judgment.” Id. If the moving party brings a factual attack on jurisdiction “by presenting affidavits or other evidence properly brought before the court, the party opposing the motion must furnish affidavits or other evidence necessary to satisfy its burden of establishing subject matter jurisdiction.” Id. DISCUSSION

Defendant moves to dismiss Plaintiff’s wrongful death claim under the Federal Torts Claims Act (”FTCA”) “[b]ecause Plaintiff . . . failed to timely exhaust administrative remedies.” Def. Mot. at 2. Plaintiff does not respond to the Motion. A federal agency may not be sued under the FTCA in its own name. 28 U.S.C. § 2679(a). The FTCA, 28 U.S.C. §§ 1346(b), 2671 et seq., provides the exclusive remedy for actions for personal injury and wrongful death caused by the allegedly

negligent acts and omissions of federal agencies and employees. See 28 U.S.C. §§ 1346(b), 2679(b)(1). The United States is the proper defendant in such actions. Id. The United States, a sovereign entity, enjoys sovereign immunity and “may not be sued without its consent.” United States v. Mitchell, 463 U.S. 206, 212 (1983). The FTCA provides a limited waiver of “the United States’ sovereign immunity for tort actions and vests the federal district courts with exclusive jurisdiction over suits

arising from the negligence of government employees.” Junio v. Vassilev, 858 F.3d 1242, 1244 (9th Cir. 2017) (citation omitted). “Absent [this] waiver, sovereign immunity shields the Federal Government and its agencies from suit.” Fed. Deposit Ins. Co. v. Meyer, 510 U.S. 471, 475 (1994).

The U.S. Forest Service is a federal agency of the United States. Plaintiff cannot bring a tort action against the U.S. Forest Service. But she can sue the United States, on behalf of the U.S. Forest Service, by bringing her tort claim against the United States in federal court—not state court—under the FTCA. Because the FTCA provides the exclusive remedy for tort claims against the United States, that is the only way Plaintiff can sue the United States on behalf of the U.S. Forest Service.

However, before Plaintiff can bring her suit in federal court, she must first exhaust her administrative remedies by “giv[ing] the appropriate federal agency the opportunity to resolve the claim.” Cadwalder v. United States, 45 F.3d 297, 300 (9th Cir. 1995); 28 U.S.C. § 2675(a). To exhaust her administrative remedies, Plaintiff must present her claim in writing to the appropriate agency, in this case, the U.S. Forest Service, and she must do so within two years after the claim accrues. 28 U.S.C. §§ 2401(b), 2675(a). A claim accrues “when a plaintiff knows or has reason to know

of the injury which is the basis of his action.” Hensley v. United States, 531 F.3d 1052, 1056 (9th Cir. 2008). Further, after presenting her claim to the appropriate federal agency, a plaintiff still cannot sue the United States until the agency has either denied her claim or has failed to issue a decision on the claim within six months of the claim being presented. 28 U.S.C. § 2675(a). Only then does a federal court have jurisdiction to hear a plaintiff’s claim. The FTCA’s administrative exhaustion requirement prevents a court from exercising jurisdiction to hear the plaintiff’s claim, and that requirement cannot be waived. Cadwalder, 45 F.3d at 300 (the FTCA “administrative claim prerequisite is

jurisdictional”); Vacek v.

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Related

United States v. Mitchell
463 U.S. 206 (Supreme Court, 1983)
McNeil v. United States
508 U.S. 106 (Supreme Court, 1993)
Federal Deposit Insurance v. Meyer
510 U.S. 471 (Supreme Court, 1994)
Mildred Jerves v. United States
966 F.2d 517 (Ninth Circuit, 1992)
Hensley v. United States
531 F.3d 1052 (Ninth Circuit, 2008)
Safe Air for Everyone v. Meyer
373 F.3d 1035 (Ninth Circuit, 2004)
D.L. ex rel. Junio v. Vassilev
858 F.3d 1242 (Ninth Circuit, 2017)

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