## Facts

- Henry Winston, a federal prisoner at Terre Haute, developed worsening neurological and vision symptoms beginning in April 1959.
- Prison medical staff initially diagnosed borderline hypertension, advised weight loss, and later provided only limited symptomatic treatment despite repeated complaints.
- An outside physician eventually evaluated Winston; surgery in early 1960 removed a benign brain tumor, but Winston’s sight could not be saved.
- Winston alleged prison employees’ negligence delayed diagnosis and treatment and caused his blindness.
- Carlos Muniz, a federal prisoner at Danbury, was assaulted by multiple inmates in August 1959, sustaining injuries.
- Muniz alleged prison officials negligently supervised inmates and failed to protect him from foreseeable violence.
- Both prisoners sued the United States for damages under the Federal Tort Claims Act (FTCA), alleging negligent acts or omissions by federal employees during confinement.

## Issues

1. Whether the FTCA allows a federal prisoner to recover damages from the United States for personal injuries sustained during confinement due to negligence of a government employee.
2. Whether principles associated with Feres v. United States bar FTCA suits by federal prisoners based on injuries arising in federal custody.
3. Whether prisoners’ claims satisfy the FTCA’s “private person” and “law of the place” requirements for liability.

## Decision

- The Supreme Court affirmed the judgment allowing both actions to proceed.
- The Court held that a federal prisoner may sue under the FTCA for injuries sustained during confinement resulting from negligent acts or omissions of government employees.
- The Court declined to extend Feres to create a categorical bar for prisoner FTCA claims.
- The Court rejected an implied “prisoner exception” absent from the statute’s enumerated exceptions.

## Legal Principles

- The FTCA waives sovereign immunity for personal injury caused by the negligent or wrongful act or omission of a government employee acting within the scope of employment, when a private person would be liable under the law of the place where the act or omission occurred.
- Feres’s bar on suits for injuries “incident to service” does not, by itself, preclude FTCA claims by federal prisoners injured in custody.
- Courts should not infer categorical exclusions from the FTCA beyond the exceptions Congress expressly listed; policy concerns about burdensome litigation do not justify judicial creation of additional immunity.

## Conclusion

Federal prisoners may pursue FTCA damages claims for injuries caused by negligent conduct of federal prison employees when the claim meets the statute’s private-person and local-law predicates and is not otherwise barred by an express FTCA exception; custody status alone does not foreclose suit.


United States v. Muniz, 374 U.S. 150 (1963)