Ali v. Federal Bureau of Prisons

Summary

The Supreme Court held that 28 U.S.C. § 2680(c)'s exception to the Federal Tort Claims Act's waiver of sovereign immunity for the 'detention' of property by 'any other law enforcement officer' covers all law enforcement officers, not merely those enforcing customs or excise laws; because Bureau of Prisons officers fall within the exception, Ali's FTCA claim for roughly $177 in lost property was properly dismissed for lack of subject-matter jurisdiction. Justice Thomas's majority relied on the naturally expansive meaning of 'any,' the disjunctive structure that defeats ejusdem generis, the absence of any common attribute supporting noscitur a sociis, and the coherence of the 2000 CAFRA amendments. Justice Kennedy, joined by Justices Stevens, Souter, and Breyer, dissented, arguing that text, interpretive canons, legislative history, and CAFRA confine the exception to customs and excise functions; Justice Breyer, joined by Justice Stevens, wrote separately to emphasize drafting history and the orders-of-magnitude sweep of the majority's reading.