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Al-Sheikh v. United States Government

2026-08-18

Summary

Holding. The court granted the government's motion to dismiss and denied the plaintiff's motions for a preliminary injunction, leave to amend the complaint, and other miscellaneous relief.

A U.S. citizen detained by the military in Iraq from 2017 to 2018 as an alleged enemy combatant sued the United States after his release, seeking damages and various forms of relief for alleged harsh detention conditions and subsequent difficulties. The plaintiff invoked multiple legal theories, including tort claims under the Federal Tort Claims Act, constitutional claims under the Fifth and Fourteenth Amendments, and statutory remedies including Bivens, sections 1983 and 1985(3), and the Administrative Procedure Act.

The court found that the plaintiff's claims were barred by jurisdictional and substantive defects. The FTCA claims failed because the plaintiff did not exhaust administrative remedies before filing suit and because the injuries occurred abroad, falling within the FTCA's foreign-country exception to sovereign immunity. Constitutional damages claims could not proceed because the United States has not waived sovereign immunity for such claims, Bivens did not apply (the only named defendants were the government and its agencies, not individual officers), and extending Bivens in the national security and military detention context would be inappropriate given Congress's role. Other statutory theories similarly provided no basis for relief due to jurisdictional limitations or the absence of private rights of action. The plaintiff's requests for injunctive and declaratory relief under the APA were also unavailing, as the passport claim was moot and other requests identified no reviewable final agency action.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether the Federal Tort Claims Act waives sovereign immunity for detention claims arising from injuries suffered abroad
  • Whether a Bivens cause of action may be recognized for constitutional claims arising from military detention overseas
  • Whether the plaintiff exhausted administrative remedies required under the FTCA before filing suit
  • Whether the Administrative Procedure Act provides a basis for relief where no final agency action or reviewable decision is identified

Procedural posture

The plaintiff, proceeding pro se, filed suit in October 2025 against the United States and its agencies seeking damages and equitable relief for detention from 2017 to 2018; the court considers the government's motion to dismiss and the plaintiff's various cross-motions.

Authorities cited

Opinion

majority opinion

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

ABDULRAHMAN AL-SHEIKH,

Plaintiff,

v. Case No. 25-cv-3704 (TSC)

UNITED STATES,

Defendant.

MEMORANDUM OPINION

Plaintiff Abdulrahman Al-Sheikh, a United States citizen residing in Bahrain, brings tort,

constitutional, and statutory claims against the United States, based on his military detention in

Iraq and difficulties he alleges he has faced since his release in 2018. Before the court is

Defendant’s motion to dismiss, ECF No. 40, along with Plaintiff’s motion for a preliminary

injunction, ECF No. 33, motion for leave to amend, ECF No. 51, and various other motions. For

the following reasons, the court will GRANT Defendant’s motion to dismiss and DENY Plaintiff’s

motions.

I. BACKGROUND

Plaintiff’s claims arise from his detention from 2017 to 2018 in Iraq by the United States

military after the Department of Defense determined he was an enemy combatant for ISIL. See

Doe v. Mattis, 928 F.3d 1, 3 (D.C. Cir. 2019). He alleges that he endured “a year and a half of

harsh detention under inhumane conditions,” including confinement in a “completely enclosed

metallic solitary cell” with lights that “remained on 24 hours a day” and an air-conditioning system

“used in a torturous manner,” and that the resulting harm “remains ongoing—physically, mentally,

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and materially.” Compl. at 2–3, ECF No. 1. In 2017, Plaintiff petitioned for a writ of habeas

corpus challenging his detention. See Mattis, 928 F.3d at 6. After the parties stipulated that the

Department of Defense released Plaintiff in Bahrain in October 2018, the court dismissed the

action with prejudice. See Doe v. Mattis, No. 17-cv-2069, ECF Nos. 125, 126.

Proceeding pro se, Plaintiff filed this action in October 2025 against the United States and

its agencies, invoking the Fifth and Fourteenth Amendments; the Federal Tort Claims Act (FTCA),

28 U.S.C. §§ 1346(b), 2671–2680; Bivens v. Six Unknown Named Agents, 403 U.S. 388 (1971);

42 U.S.C. §§ 1983 and 1985(3); 18 U.S.C. §§ 242 and 4001(a); the Privacy Act, 5 U.S.C. § 552a;

the Administrative Procedure Act (APA), 5 U.S.C. §§ 701–706; and various treaties, among other

authorities. He seeks damages and broad equitable and declaratory relief.

II. LEGAL STANDARD

A motion under Rule 12(b)(1) tests the court’s subject-matter jurisdiction. The United

States may be sued only where it has waived sovereign immunity, and any waiver “must be

unequivocally expressed in statutory text.” Lane v. Peña, 518 U.S. 187, 192 (1996). Plaintiffs

bear the burden of establishing the existence of a waiver, which is a jurisdictional prerequisite.

See FDIC v. Meyer, 510 U.S. 471, 475 (1994).

A motion under Rule 12(b)(6) tests whether a complaint “contain[s] sufficient factual

matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal,

556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). The

court accepts well-pleaded factual allegations as true but disregards “legal conclusion[s] couched

as . . . factual allegation[s].” Iqbal, 556 U.S. at 678 (quoting Twombly, 550 U.S. at 555). Rule 8

requires a “short and plain statement of the claim showing that the pleader is entitled to relief,” set

forth in “simple, concise, and direct” allegations. Fed. R. Civ. P. 8(a)(2), (d)(1).

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The court construes pro se filings liberally, Erickson v. Pardus, 551 U.S. 89, 94 (2007),

and considers all filings submitted by a pro se litigant in assessing a complaint, see Brown v. Whole

Foods Mkt. Grp., Inc., 789 F.3d 146, 152 (D.C. Cir. 2015). But liberal construction cannot supply

a waiver Congress has not enacted or state a claim where the pleadings do not.

III. ANALYSIS

Plaintiff’s FTCA claims suffer from fatal jurisdictional defects. To begin, he failed to

exhaust his administrative remedies. See McNeil v. United States, 508 U.S. 106, 113 (1993) (“The

FTCA bars claimants from bringing suit in federal court until they have exhausted their

administrative remedies.”); see Simpkins v. District of Columbia Government, 108 F.3d 366, 371

(D.C. Cir. 1997). 28 U.S.C. § 2675(a) sets out the FTCA’s exhaustion requirement: a plaintiff

cannot sue “unless the claimant [has] first presented the claim to the appropriate Federal agency

and his claim [has] been finally denied by the agency in writing and sent by certified or registered

mail.” Plaintiff mailed his administrative claims to the appropriate agencies in May 2026, seven

months after filing this action. See ECF Nos. 1, 48. His tort claims are therefore premature, and

that defect cannot be remedied by amendment. See Edwards v. D.C., 616 F. Supp. 2d 112, 117

(D.D.C. 2009). And even assuming administrative exhaustion, Plaintiff’s FTCA claims arise from

injuries suffered abroad, and the FTCA’s waiver of sovereign immunity does not apply to claims

“arising in a foreign country.” 28 U.S.C. § 2680(k); see also Sosa v. Alvarez-Machain, 542 U.S.

692, 712 (2004) (“[T]he FTCA’s foreign country exception bars all claims based on

any injury suffered in a foreign country, regardless of where the tortious act or omission

occurred.”).

As to Plaintiff’s constitutional claims for damages, the United States has not waived its

sovereign immunity. See Meyer, 510 U.S. at 477. Plaintiff’s attempt to invoke Bivens—which

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creates a cause of action, in limited contexts, to sue federal officials in their personal capacities for

damages arising from constitutional violations—fails on its face, as the only named Defendants

are the United States and its agencies. See Bivens, 403 U.S. at 389. But even had Plaintiff named

individual officers, the court would not imply a Bivens remedy here. Recognizing a new Bivens

context is “‘a disfavored judicial activity,’” unavailable whenever “there is any reason to think that

Congress might be better equipped to create a damages remedy.” Egbert v. Boule, 596 U.S. 482,

491–92 (2022) (quoting Ziglar v. Abbasi, 582 U.S. 120, 135 (2017)). While courts take a “caseby-case approach in determining whether to recognize a Bivens cause of action,” “cases involving

national security and the military counsel[] hesitation in recognizing a Bivens cause of action where

Congress has not done so.” Meshal v. Higginbotham, 804 F.3d 417, 422 (D.C. Cir. 2015). The

D.C. Circuit has already refused to extend Bivens to claims of unlawful detention and mistreatment

during an overseas terrorism investigation. See id. at 426–27. The same special factors—national

security, military detention, and extraterritorial injury—counsel hesitation before authorizing a

new kind of federal litigation here. See id. at 421–26; Doe v. Rumsfeld, 683 F.3d 390, 395–96

(D.C. Cir. 2012).

Plaintiff’s other statutory theories likewise provide no basis for relief. Section 1983 applies

only to persons acting “‘under color’ of” state, territorial, or D.C. law; it “does not apply to federal

officials acting under color of federal law.” Settles v. U.S. Parole Comm’n, 429 F.3d 1098, 1104

(D.C. Cir. 2005). Section 1985(3) likewise does not apply to actions against the United States.

See Hohri v. United States, 782 F.2d 227, 245 n.43 (D.C. Cir. 1986), vacated on other grounds

sub nom. United States v. Hohri, 482 U.S. 64 (1987). And neither 18 U.S.C. § 4001(a) nor § 242

confer a private right of action. See Bailey v. Bureau of Prisons, 133 F. Supp. 3d 50, 55 (D.D.C.

2015); Ballard v. Kendall, 640 F. Supp. 3d 41, 55 (D.D.C. 2022). Finally, Plaintiff fails to state a

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claim under the Privacy Act: he neglects to identify an agency record or allege denial of access or

amendment, unauthorized disclosure, adverse determination based on an inaccurate record, or

other actionable violation. See 5 U.S.C. § 552a(a)(4), (b), (d)(1)–(3), (e)(5), (g)(1)(A)–(D).

Plaintiff’s attempt to invoke the APA’s waiver of sovereign immunity for actions “seeking

relief other than money damages” is also unavailing. 5 U.S.C. § 702; see ECF No. 23. The State

Department issued him a passport in 2023, mooting any claim under 5 U.S.C. § 706(1) based on

the alleged delay in processing his passport application. See Compl. at 3. His requests for

additional consular assistance identify neither a “discrete agency action that [the Department] is

required to take,” Norton v. S. Utah Wilderness All., 542 U.S. 55, 64 (2004), nor final agency

action, see 5 U.S.C. § 704; Bennett v. Spear, 520 U.S. 154, 177–78 (1997). His request to correct

unspecified watchlist “listings” alleges no facts suggesting that he appears on any such list much

less that an agency has taken or unlawfully withheld reviewable action concerning a listing. ECF

No. 23 at 91. And his requests that the court order a federal investigation or declare void an

“executive decision granting diplomatic immunity to Ahmad Al-Shar’a” are not justiciable. Id. at

76. “[A]n agency’s decision not to prosecute or enforce, whether through civil or criminal process,

is a decision generally committed to an agency’s absolute discretion,” Heckler v. Chaney, 470 U.S.

821, 831 (1985), and “a private citizen lacks a judicially cognizable interest in the prosecution or

nonprosecution of another,” Linda R.S. v. Richard D., 410 U.S. 614, 619 (1973).

Nor do the Declaratory Judgment Act, 28 U.S.C. §§ 2201–2202, the All Writs Act, 28

U.S.C. § 1651(a), or the Mandamus Act, 28 U.S.C. § 1361, supply Plaintiff an independent basis

for relief or jurisdiction. Absent “a cognizable cause of action,” Plaintiff has “no basis upon which

to seek declaratory relief.” Ali v. Rumsfeld, 649 F.3d 762, 778 (D.C. Cir. 2011). And the All Writs

Act authorizes writs only “in aid of” jurisdiction otherwise established, 28 U.S.C. § 1651(a); it

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“does not operate as a waiver of sovereign immunity,” Holt v. Davidson, 441 F. Supp. 2d 92, 96

(D.D.C. 2006). Mandamus is a “drastic” and “extraordinary” remedy, Allied Chemical Corp. v.

Daiflon, Inc., 449 U.S. 33, 34 (1980), available only where “(1) the plaintiff has a clear right to

relief; (2) the defendant has a clear duty to act; and (3) there is no other adequate remedy available

to plaintiff,” Power v. Barnhart, 292 F.3d 781, 784 (D.C. Cir. 2002) (quoting Northern States

Power Co. v. Dep’t of Energy, 128 F.3d 754, 758 (D.C. Cir. 1997)). Plaintiff, as discussed above,

has identified no such duty.

Plaintiff also seeks a preliminary injunction to address safety concerns related to Iranian

drone and missile attacks on Bahrain. ECF No. 33. He seeks an injunction “to stop . . . restrictions”

and “[s]uspend any administrative measures that impede his freedom or safety”; an order to

“[e]nable him to leave the danger zone to a safe place immediately”; and an order for “the

government to take immediate measures to protect him.” Id. at 10. But a preliminary injunction

may grant only “intermediate relief of the same character as that which may be granted finally”;

that condition is not satisfied when the motion “deals with a matter lying . . . outside the issues in

the suit.” De Beers Consol. Mines v. United States, 325 U.S. 212, 220 (1945). The Complaint

predates the 2026 military conflict with Iran, meaning any relief premised on that conflict falls

outside the allegations in the Complaint. Plaintiff’s other requests for interim injunctive relief to

lift administrative restrictions he alleges prevent him and his daughter from fleeing hostilities in

Bahrain similarly fall outside the scope of this action. ECF Nos. 26, 30.

In the alternative, Plaintiff requests leave to amend his Complaint. ECF No. 51. But he

fails to attach a proposed amended complaint as this District’s local rules require. See Local Civ.

R. 7(i), 15.1; Rollins v. Wackenhut Servs., Inc., 703 F.3d 122, 130 (D.C. Cir. 2012). And in any

case, amendment would be futile: it cannot cure the absence of a waiver of sovereign immunity,

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the FTCA’s exhaustion requirement, or the unavailability of a Bivens remedy. See, e.g.,

Willoughby v. Potomac Elec. Power Co., 100 F.3d 999, 1003 (D.C. Cir. 1996) (“[L]eave to amend

should be freely given unless there is a good reason, such as futility, to the contrary.”).

Plaintiff’s remaining miscellaneous motions are meritless. He seeks to compel the

American Civil Liberties Union, a non-party, to produce records, ECF No. 22, but “it

is well settled that discovery is generally considered inappropriate while a motion that would be

thoroughly dispositive of the claims in the Complaint is pending,” Institut Pasteur v. Chiron

Corp., 315 F. Supp. 2d 33, 37 (D.D.C. 2004) (cleaned up). His motions for entry of default, ECF

Nos. 31, 32, fail because the Government responded within the extended time the court allowed;

his motions to expedite, ECF Nos. 15, 34, 35, 38, 59, and the Government’s objection to the

related-case designation, ECF No. 39, are moot in light of this disposition. His request for

appointment of counsel, Compl. at 10, will be denied given the absence of any viable claim.

IV. CONCLUSION

For the foregoing reasons, the court will GRANT the Government’s motion to dismiss.

ECF No. 40. The court will DENY Plaintiff’s motion to compel production, ECF No. 22; motion

for declaratory and equitable relief, ECF No. 23; motion for a preliminary injunction, ECF No. 33;

further motions or requests for interim relief, ECF Nos. 26, 30; motions for entry of default, ECF

Nos. 31, 32; and motion for leave to amend, ECF No. 51. The Government’s objection to the

related-case designation, ECF No. 39, and Plaintiff’s remaining miscellaneous motions and

requests, ECF Nos. 13, 15, 18, 34, 35, 38, 43, 48, and 59, will be DENIED or terminated as moot.

To the extent the Complaint requests appointment of counsel, that request will be DENIED.

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Date: August 18, 2026

Tanya S. Chutkan

TANYA S. CHUTKAN

United States District Judge

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