Manansingh v. United States
2:20-cv-01139
| D. Nev. | Jun 24, 2025Background
- Plaintiffs, Chandan Manansingh and Angela Nairns, brought FTCA claims against the United States based on an April 2016 probation search of their home and related events following Manansingh's 2013 criminal conviction for introducing misbranded drugs into interstate commerce.
- The remaining claims at trial were for intentional infliction of emotional distress (IIED) and abuse of process, after prior pretrial rulings dismissed other claims and defendants.
- Manansingh alleged the probation search, subsequent arrest, and prosecution were motivated by animus and involved fabrication of evidence and misconduct by probation officers; Nairns claimed emotional distress and abuse of process based on repeated subpoena service.
- The search of Manansingh’s home was based on positive steroid tests and alleged violations of his supervision conditions, but a criminal court later found the search lacked reasonable suspicion and suppressed the evidence.
- The bench trial focused on whether the actions of the probation officers amounted to extreme or outrageous conduct or constituted abuse of legal process under Nevada law.
- The court made extensive credibility findings, ultimately finding the probation officers and prosecutor credible and determining that plaintiffs failed to carry their burden of proof.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Intentional Infliction of Emotional Distress | Officers’ conduct during the search, arrest, and prosecution was extreme, outrageous, racially charged, and fabricated evidence | Officers acted professionally and within the scope of supervision; no extreme or outrageous conduct or fabrication occurred | For Defendant; No extreme or outrageous conduct |
| Abuse of Process | Officers and AUSA used process (search, subpoenas, prosecution) for an improper, personal vendetta | Legal process used within its authorized scope for legitimate supervision and prosecution purposes | For Defendant; No ulterior purpose or willful act |
| Administrative Exhaustion | Plaintiffs timely filed administrative claims with DOJ for FTCA purposes | Nairns’ claims time-barred for failure to file within two years of accrual | For Defendant; Nairns' claims barred |
| Preclusive Effect of Suppression Ruling | Suppression order in the criminal case should preclude government from relitigating lack of reasonable suspicion | Suppression ruling does not bind this FTCA action; issues and records are different and do not control FTCA tort claims | For Defendant; No preclusive effect |
Key Cases Cited
- Bivens v. Six Unknown Named Agents of Fed. Bureau of Narcotics, 403 U.S. 388 (authorizes certain constitutional tort claims against federal agents)
- Star v. Rabello, 625 P.2d 90 (Nev. 1981) (outlines elements for intentional infliction of emotional distress under Nevada law)
- Olivero v. Lowe, 995 P.2d 1023 (Nev. 2000) (elaborates on IIED standards)
- Posadas v. City of Reno, 851 P.2d 438 (Nev. 1993) (explains abuse of process elements under Nevada law)
- Allen v. McCurry, 449 U.S. 90 (1980) (federal upholding of collateral estoppel principles in civil and criminal contexts)