## Facts

- Abdus-Shahid M. S. Ali, a federal prisoner, was transferred from a federal prison in Atlanta, Georgia, to a federal prison in Inez, Kentucky.
- Bureau of Prisons (BOP) personnel packed Ali’s belongings into two duffel bags and shipped them to the receiving facility.
- After arrival, Ali reported that several personal items were missing, with an alleged value of about $177.
- Ali filed an administrative tort claim with the BOP alleging loss or misappropriation of his property; the claim was denied, including on the ground that Ali had signed a property receipt.
- Ali sued the United States under the Federal Tort Claims Act (FTCA), seeking damages for the missing property.

## Issues

1. Whether the FTCA’s “detention of goods” exception, 28 U.S.C. § 2680(c), applies to the detention of property by BOP officers.
2. Whether the phrase “any other law enforcement officer” in § 2680(c) is limited to officers acting in customs/excise or tax-related functions, or instead includes all federal law enforcement officers.

## Decision

- The Supreme Court affirmed the Eleventh Circuit’s judgment and held, 5–4, that § 2680(c) bars Ali’s FTCA claim.
- The Court interpreted “any other law enforcement officer” to include law enforcement officers of whatever kind, not only customs or excise officers.
- Because BOP officers are “law enforcement officer[s]” within § 2680(c), the United States retained sovereign immunity for claims arising from the detention (and resulting loss) of Ali’s property.

## Legal Principles

- The FTCA’s waiver of sovereign immunity is subject to statutory exceptions that courts apply according to the text of 28 U.S.C. § 2680.
- Under § 2680(c), a claim “arising in respect of” the detention of property by “any officer of customs or excise or any other law enforcement officer” is excluded from the FTCA waiver.
- The word “any,” absent limiting language, is ordinarily read broadly; thus “any other law enforcement officer” is not confined to customs- or excise-related enforcement.
- Contextual references in § 2680(c) to taxes, customs duties, and customs/excise officers do not restrict the independent phrase “any other law enforcement officer.”
- When statutory text is clear, the Court does not rely on legislative history to narrow the statute’s meaning.

## Conclusion

The Court held that the FTCA does not authorize suits for property loss arising from the detention of goods by Bureau of Prisons officers because § 2680(c) preserves sovereign immunity for such claims involving detention by any federal law enforcement officer.


Ali v. Fed. Bureau of Prisons, 552 U.S. 214 (2008)