Marlon Bramwell v. U.S. Bureau of Prisons

We must decide whether the seizure and inadvertent destruction of an inmate’s property by correctional officers gives rise to a cause of action against the U.S. Bureau of Prisons (BOP) under the Federal Tort Claims Act (FTCA), 28 U.S.C. § 2671 , et seq. We hold that the seizure in this case was a “detention” of goods by federal law enforcement officers under the exception to FTCA liability set forth in 28 U.S.C. § 2680 (c). We affirm the district court’s ruling and join the majority of circuits that have similarly interpreted this subsection.

The district court dismissed federal prisoner Marlon Bramwell’s FTCA claim against the BOP for lack of subject matter jurisdiction. On appeal, Bramwell contends that: (1) the FTCA waives sovereign immunity for claims of property damage by BOP officers; (2) a “detention of goods” occurs only if officers knowingly and intentionally detain a person’s property; (3) the district court erred by denying his motion to amend his pleadings to substitute the United States as the defendant; and (4) the district court improperly denied his motion for reconsideration.

I

After Bramwell was moved to administrative segregation at a federal prison, BOP…