Allgeier V. United States

We face three principal issues in this appeal of a post-trial judgment awarding damages against the United States on two related claims under the Federal Torts Claims Act (FTCA), 28 U.S.C. § 2671 et seq. First, the government claims that plaintiff Richard Allgeier's amended complaint, which correctly named the United States as the sole defendant but only after the FTCA statute of limitations expired, did not secure federal jurisdiction over his claim by relating back to the original timely but misdirected complaint under Fed. R. Civ. P. 15(c). Second, the government claims that the trial court erred in finding that exceptional circumstances justified allowing intervening plaintiff Maria Boldrick to enter deposition testimony into evidence. Third, the government contends that the trial court erred in finding a sufficient basis for awarding damages to Boldrick in excess of her initial claim before the administrative agency. We hold that Allgeier's amended complaint did not relate back and thus failed to remedy the jurisdictional defect of his original complaint. We also uphold the two challenged findings regarding Boldrick's suit. Lastly, we reject the United States' argument that the district court lacked jurisdiction over Boldrick's claim. We thus reverse Allgeier's judgment against the United States and affirm Boldrick's.