Woodruff v. United States of America, Civil Action No. 2016-1884

Background

Plaintiff Tyrell Woodruff, a former inmate at FCI Gilmer, alleges he was stabbed multiple times by another inmate in the recreation yard on January 13, 2015, and that staff failed to intervene for ~20 minutes.
Woodruff sued the United States under the Federal Tort Claims Act (FTCA) for negligence, claiming inadequate security and failure of officers to stop the attack; he seeks $500,000.
The government moved to dismiss for lack of subject-matter jurisdiction, invoking the FTCA’s discretionary function exception.
Central factual/legal dispute: whether Bureau of Prisons (BOP) program statements or FCI Gilmer post orders imposed mandatory duties on staff that would preclude the discretionary function exception.
Woodruff requested limited jurisdictional discovery to obtain post orders and specified BOP program statements; the government opposed broad discovery but did not oppose limited document production.
The Court denied the motion to dismiss as premature, granted limited jurisdictional discovery (specified program statements and FCI Gilmer post orders in effect on Jan. 13, 2015), dismissed the BOP as a defendant, and set discovery and status-report deadlines.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the discretionary function exception bars the FTCA claim	Woodruff contends specific BOP program statements and FCI post orders create mandatory duties to supervise/restrict recreation and to intervene, removing discretion	Gov’t contends no statute/regulation/post order required a specific course of action; response and security decisions are discretionary and policy-based	Denied dismissal as premature; allowed limited jurisdictional discovery to determine whether mandatory duties exist
Whether internal BOP/FCI documents are necessary to resolve jurisdiction	Woodruff says those documents may show mandatory obligations and are essential to rebut the exception	Gov’t argues prison officials generally have discretion and discovery is unnecessary or should be narrowly tailored	Court held plaintiff entitled to limited jurisdictional discovery of identified documents
Scope of permitted discovery	Woodruff sought post orders, specified program statements, plus rosters, disciplinary reports, security upgrade records	Gov’t agreed discovery should be limited to the specific program statements and Recreation Yard post orders; objected to broader categories	Court limited discovery to the program statements listed by Woodruff and FCI Gilmer post orders for Jan. 13, 2015; denied broader discovery as irrelevant to discretionary-function inquiry
Proper defendant(s)	Complaint named United States and BOP	Gov’t moved to dismiss; Plaintiff clarified he sued only the United States	Court dismissed the Federal Bureau of Prisons as a defendant

Key Cases Cited

Herbert v. Nat’l Acad. of Scis., 974 F.2d 192 (D.C. Cir.) (district court may consider record facts on Rule 12(b)(1) motion)
Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375 (plaintiff bears burden to establish jurisdiction)
FDIC v. Meyer, 510 U.S. 471 (sovereign immunity shields federal government absent waiver)
United States v. Mitchell, 463 U.S. 206 (consent to be sued is jurisdictional prerequisite)
United States v. Sherwood, 312 U.S. 584 (terms of waiver define court’s jurisdiction)
Sloan v. U.S. Dep’t of Hous. & Urban Dev., 236 F.3d 756 (FTCA waives immunity for certain employee torts)
United States v. Gaubert, 499 U.S. 315 (two-part discretionary function test)
Berkovitz v. United States, 486 U.S. 531 (first-step inquiry whether statute/regulation prescribes specific action)
Cope v. Scott, 45 F.3d 445 (discretionary function determinations are jurisdictional)
Sledge v. United States, 723 F. Supp. 2d 87 (prisoner-safety cases examine program statements/post orders to identify mandatory duties)
Ignatiev v. United States, 238 F.3d 464 (plaintiff entitled to discovery of internal guidelines to establish jurisdiction)
Loughlin v. United States, 393 F.3d 155 (limited jurisdictional discovery may be appropriate to challenge discretionary-function exception)