Timothy Taylor v. United States

Court of Appeals for the Fourth Circuit·Decided August 11, 2026·No. 25-1570·Unpublished

Opinion

UNPUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 25-1570

TIMOTHY DASHAUN TAYLOR, Plaintiff – Appellant,

v.

UNITED STATES OF AMERICA, Defendant – Appellee.

Appeal from the United States District Court for the District of South Carolina, at Charleston. Bruce H. Hendricks, District Judge. (2:24-cv-01440-BHH)

Argued: May 5, 2026 Decided: August 11, 2026

Before DIAZ, Chief Judge, and HARRIS and BENJAMIN, Circuit Judges.

Affirmed by unpublished opinion. Judge Harris wrote the opinion, in which Chief Judge Diaz and Judge Benjamin joined.

ARGUED: Matthew Ryan McKaig, MCKAIG LAW FIRM LLC, Charleston, South Carolina, for Appellant. Kimberly Varadi Hamlett, OFFICE OF THE UNITED STATES ATTORNEY, Charleston, South Carolina, for Appellee. ON BRIEF: Bryan P. Stirling, United States Attorney, Joanna B. Stroud, Assistant United States Attorney, OFFICE OF THE UNITED STATES ATTORNEY, Charleston, South Carolina, for Appellee.

Unpublished opinions are not binding precedent in this circuit.

PAMELA HARRIS, Circuit Judge:

Plaintiff Timothy Dashaun Taylor, a black man, alleges that he faced a years-long, highly public FBI investigation for the notorious kidnapping and murder of a young white woman. As alleged, the FBI investigated and publicly accused Taylor of this crime despite the fact that FBI agents knew he was not the perpetrator, and even as they neglected to pursue the white man who ultimately confessed to the crime. Taylor sued the United States under the Federal Tort Claims Act (“FTCA”), 28 U.S.C. §§ 1346(b), 2671–2680, for economic and emotional damages stemming from the FBI’s allegedly faulty investigation.

The district court dismissed Taylor’s suit on multiple grounds, relying chiefly, but not exclusively, on the FTCA’s “discretionary function” exception. On appeal, Taylor fails to challenge the court’s dispositive rulings. For that reason, we must affirm the district court’s dismissal of Taylor’s complaint.

I.

A.

We briefly recount the troubling allegations in Timothy Taylor’s complaint, which at this stage we accept as true and construe in the light most favorable to Taylor. See Kerns v. United States, 585 F.3d 187, 192 (4th Cir. 2009).

In April 2009, a 17-year-old woman named Brittanee Drexel went missing in Myrtle Beach, South Carolina. That day, Timothy Taylor (whom we refer to as “Taylor”) and his father, Shaun, two black men, were at a car show almost four hours south of Myrtle Beach. Meanwhile, a white couple, Raymond Moody and Angel Vause, were in Myrtle Beach.

Thirteen years later, Moody – who in 2009 was already a convicted “serial rapist and kidnapper who had victimized at least seven girls” –admitted to kidnapping and killing Drexel. J.A. 10.

But when local and state police began investigating Drexel’s disappearance, they started with then-16-year-old Taylor and his father, based on what Taylor alleges was unreliable evidence. Eventually, investigators confirmed the Taylors’ car-show alibi and stopped pursuing them. And according to Taylor, local and state authorities became convinced that Moody had committed the crime but felt they lacked sufficient evidence to arrest him. So the case went cold.

About five years later, the FBI launched its own investigation. The FBI’s agents, Taylor says, knew of his confirmed alibi and local law enforcement’s belief that Moody was the culprit. Nevertheless, the FBI credited an incarcerated “violent convict” – deemed unreliable by state and local officials – who accused the Taylors of the crime without corroboration. J.A. 35. And then, because they lacked probable cause to arrest Taylor in connection with Drexel’s disappearance, the FBI instead instigated federal charges against Taylor for a McDonald’s robbery that occurred five years earlier – a crime to which Taylor had pled guilty in state court and for which he had served probation. According to Taylor, the FBI used these federal charges as “pretext” to arrest him and pressure him to confess to Drexel’s murder. J.A. 38.

The FBI compounded the harm at Taylor’s 2016 bail hearing on the federal robbery charges, when an FBI agent testified that Taylor was dangerous and should not be released because he was being investigated for “kidnapping, human trafficking and murder” in

connection with the Drexel case. J.A. 40 (internal quotation marks omitted). According to Taylor, the agent spoke “at length” and “made sure to include the most sickening, gory, and outrageous details” collected from the FBI’s jailhouse accuser. Id. The agent’s testimony was later widely publicized in the media, inflicting “immediate, massive, and generational damage to the lives of every member of the Taylor family.” J.A. 41. Taylor ultimately pled guilty to one count against him in the federal robbery case.

A few years later, in 2019, the FBI’s case against the Taylors fell apart when the jailhouse accuser changed his story, and the FBI ruled out Taylor and his father as suspects. But the FBI did not publicize that fact or correct its 2016 testimony identifying Taylor as a suspect. Only three years later, in 2022, did the harm to the Taylors finally end, when the FBI returned to the Moody lead and Moody pled guilty to Drexel’s murder.

B.

Taylor filed this suit under the Federal Tort Claims Act for harms caused by the FBI agents who investigated him and his father. The FTCA waives the United States’s sovereign immunity for certain claims against the United States “for injury or loss of property, or personal injury or death caused by the negligent or wrongful act or omission of any employee of the Government while acting within the scope of his office or employment.” 28 U.S.C. § 1346(b)(1). In such suits, the government can be held liable to the same extent as a private person would be “in accordance with the law of the place where the act or omission occurred.” Id. Because the conduct challenged in Taylor’s suit occurred in South Carolina, Taylor’s complaint alleges three South Carolina torts: abuse of process, intentional infliction of emotional distress, and negligence/gross negligence.

The district court dismissed Taylor’s suit on multiple grounds. Taylor v. United States, 2025 WL 1453961 (D.S.C. Mar. 21, 2025). Centrally, the court relied on the FTCA’s “discretionary function exception,” id. at *6, which carves out from the FTCA’s general waiver of sovereign immunity claims that are “based upon the exercise or performance or the failure to exercise or perform a discretionary function or duty . . . whether or not the discretion involved be abused,” 28 U.S.C. § 2680(a). The district court reasoned, first, that the FBI agents’ conduct in investigating and helping to prosecute Taylor on federal robbery charges implicated “criminal law enforcement decisions,” which “necessarily involved discretionary judgments or choices.” Taylor, 2025 WL 1453961, at *7. And it held, second, that the agents’ discretionary choices were grounded in public policy and thus “of the kind that the discretionary function exception was designed to shield.” Id. at *6–7 (quoting Berkovitz by Berkovitz v. United States, 486 U.S. 531, 537 (1988), and applying its two-step analysis).

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