Al Shimari v. Caci International, Inc., 658 F.3d 413

Four Iraqi detainees alleged CACI contractors, working with U.S. military personnel at Abu Ghraib, conspired to torture and cover up abuse during interrogations.
Plaintiffs asserted state-law tort claims including assault, battery, sexual assault, intentional/negligent infliction of emotional distress, and negligent hiring/supervision.
The district court denied dismissal and allowed limited discovery regarding immunity and preemption defenses.
On interlocutory appeal, the Fourth Circuit reversed and remanded with instructions to dismiss based on federal preemption and displacement of state law under Boyle and Saleh.
The court held that tort claims arising from contractor-integrated wartime interrogation activities conflict with uniquely federal interests and are preempted.
The opinion emphasizes the war-zone context, the military’s command authority, and the need for military discretion over interrogation policies.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Are the plaintiffs' state-law tort claims preempted by federal law?	Plaintiffs contend state tort law should apply; no exclusive federal preemption on wartime contractor actions.	Preemption under Boyle/Saleh applies; contractor activities integrated with military operations are displaced by federal war-time interests.	Yes; claims are preempted and displaced, warranting dismissal.

Boyle v. United Technologies Corp., 487 U.S. 500 (Supreme Court, 1988) (design-discretionary function preemption; uniquely federal interests can displace state tort duties)
Saleh v. Titan Corp., 580 F.3d 1 (D.C. Cir., 2009) (combatant activities preemption; battlefield preemption principle for contractors)
Mangold v. Analytic Services, Inc., 77 F.3d 1442 (4th Cir., 1996) (derivative absolute immunity for government contractors in certain investigations)