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Thomas Carruthers v. U.S. Transportation Security Administration

2026-08-31

Summary

Holding. The district court granted the TSA's motion to dismiss and dismissed the action for lack of subject matter jurisdiction based on failure to exhaust administrative remedies, the FTCA's intentional tort exception, and improper naming of the defendant.

Debra Irene Thomas Carruthers filed suit against the Transportation Security Administration, seeking $80,000 in damages for injuries sustained during a pat-down screening at Ronald Reagan Washington National Airport in June 2024. She alleged that a TSA officer improperly conducted the screening, causing her physical harm that required subsequent medical treatment. The TSA moved to dismiss the complaint for lack of subject matter jurisdiction and failure to state a claim.

The district court granted the TSA's motion to dismiss on three independent jurisdictional grounds under the Federal Tort Claims Act. First, Carruthers failed to exhaust available administrative remedies by presenting her claim to the TSA before filing suit. Second, the FTCA excludes intentional torts such as assault and battery from its sovereign immunity waiver, and Carruthers's allegations fell within this carve-out. Third, Carruthers sued the TSA as the defendant when FTCA actions must be brought against the United States itself. The court determined it lacked subject matter jurisdiction and declined to appoint counsel to assist the pro se litigant.

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

Key issues

  • Whether administrative remedies must be exhausted before bringing a Federal Tort Claims Act suit
  • Whether the FTCA's exception for intentional torts bars the plaintiff's assault and battery allegations
  • Whether an agency may be sued directly under the FTCA or only the United States

Procedural posture

The Transportation Security Administration moved to dismiss the pro se plaintiff's Federal Tort Claims Act complaint for lack of subject matter jurisdiction and failure to state a claim.

Authorities cited

Opinion

majority opinion

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

DEBRA IRENE THOMAS CARRUTHERS,

Plaintiff,

v.

No. 25-cv-01763 (DLF)

TRANSPORTATION SECURITY

ADMINISTRATION,

Defendant.

MEMORANDUM OPINION

Debra Irene Thomas Carruthers, proceeding pro se, brings this action against the

Transportation Security Administration (TSA), alleging that a TSA officer injured her during a

pat-down screening. Before the Court is TSA’s Motion to Dismiss, Dkt. 9. For the reasons that

follow, the Court will grant the motion and dismiss this action.

I. BACKGROUND

On June 5, 2024, Carruthers flew from Ronald Reagan Washington National Airport in

Virginia to Chicago Midway International Airport in Illinois. Compl. Ex., at 2, Dkt. 1-1. As part

of the security process at Reagan, Carruthers underwent a pat-down screening conducted by TSA

Officer Charita Mills. See id. Although Mills initially “follow[ed] procedure,” she proceeded to

“gra[b]” Carruthers’s “vaginal area” with her index finger and “jer[k]” her finger toward her. Id.

The action “caused [Carruthers] great pain.” Id. Carruthers reported the incident to a supervising

officer but ultimately had to leave the security area to board her flight. Id. She later underwent

pelvic floor physical therapy for injuries caused by the screening. See Compl. 4, Dkt. 1.

On June 4, 2025, Carruthers filed suit in this Court, seeking $80,000 in damages for her

“pain and discomfort.” Id. TSA has moved to dismiss her complaint for lack of jurisdiction and

failure to state a claim. See Mot. to Dismiss 1, Dkt. 9. In the alternative, TSA has asked the Court

to transfer the case to the Eastern District of Virginia pursuant to 28 U.S.C. § 1404(a). Id.

II. LEGAL STANDARD

Under Federal Rule of Civil Procedure 12(b)(1), a party may move to dismiss a claim over

which the Court lacks subject matter jurisdiction. Fed. R. Civ. P. 12(b)(1). When ruling on a Rule

12(b)(1) motion, the Court “must treat the complaint’s factual allegations as true and afford the

plaintiff the benefit of all inferences that can be derived from the facts alleged.” Han v. Lynch,

223 F. Supp. 3d 95, 103 (D.D.C. 2016) (citation modified). At the same time, the plaintiff bears

the burden of establishing subject matter jurisdiction. See Arpaio v. Obama, 797 F.3d 11, 19 (D.C.

Cir. 2015); see also Fed. R. Civ. P. 8(a)(1) (“A pleading that states a claim for relief must contain

. . . a short and plain statement of the grounds for the court’s jurisdiction, unless the court already

has jurisdiction and the claim needs no new jurisdictional support.”). “While complaints filed by

pro se litigants are held to less stringent standards than those applied to formal pleadings drafted

by lawyers, even a pro se plaintiff bears the burden of establishing that the Court has subject matter

jurisdiction.” Newby v. Obama, 681 F. Supp. 2d 53, 55 (D.D.C. 2010) (citation modified). If the

Court determines that it lacks subject matter jurisdiction, it must dismiss the action. Fed. R. Civ.

P. 12(h)(3).

III. ANALYSIS

The Federal Tort Claims Act (FTCA) provides a limited waiver of sovereign immunity for

certain tort claims against the United States. See 28 U.S.C. § 2674. That waiver, however, is

subject to limits. Three limitations bar Carruthers’s suit here.

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First, before bringing a tort claim under the FTCA, a plaintiff must exhaust available

administrative remedies by “present[ing]” her claim “to the appropriate Federal agency.” Id.

§ 2675(a). Administrative exhaustion occurs when the agency issues a final written denial or

remains unresponsive for six months. Id. The D.C. Circuit has “treated the FTCA’s requirement

of filing an administrative complaint with the appropriate agency prior to instituting an action as

jurisdictional.” Simpkins v. District of Columbia, 108 F.3d 366, 371 (D.C. Cir. 1997); 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.”). Carruthers has not pleaded facts

sufficient to demonstrate administrative exhaustion here. See Fed. R. Civ. P. 8(a)(1). Nor has she

responded to TSA’s argument that she failed to exhaust her administrative remedies. See Mem. in

Supp. of Mot. to Dismiss 4–5, Dkt. 9-1. As such, the Court lacks subject matter jurisdiction over

her claims. See Colbert v. USPS, 831 F. Supp. 2d 240, 243 (D.D.C. 2011).

Second, the FTCA separately claws back sovereign immunity for a subset of intentional

torts, including for “[a]ny claim arising out of” assault or battery. See 28 U.S.C. § 2680(h). As

currently pleaded, Carruthers’s allegations fall squarely within those exceptions. Accordingly,

sovereign immunity bars her claims.

Third, Carruthers has sued the wrong defendant. The United States is the only proper

defendant in an FTCA action. See id. §§ 1346(b), 2679; Johnson v. Veterans Affs. Med. Ctr., 133

F. Supp. 3d 10, 16–17 (D.D.C. 2015). Here, Carruthers has sued an agency, not the United States.

See Coulibaly v. Kerry, 213 F. Supp. 3d 93, 125 (D.D.C. 2016) (“[A] plaintiff may not bring tort

claims against federal officials in their official capacities or against federal agencies.”). “Failure

to name the United States as the defendant in an FTCA action requires dismissal for lack of subjectmatter jurisdiction.” Johnson, 133 F. Supp. 3d at 17.

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For each of these reasons, the Court lacks subject matter jurisdiction over Carruthers’s suit.

Accordingly, the Court will dismiss the action. See Fed. R. Civ. P. 12(h)(3).

Finally, the Court notes that Carruthers has represented in filings that she has had difficulty

litigating this case pro se. See, e.g., Mot. for Extension of Time 1, Dkt. 10. To the extent that

Carruthers requests that the Court appoint counsel to represent her, the Court declines to do so.

“The law is well established that there is no constitutional right to appointment of counsel in a civil

case, and no indigent civil litigant is guaranteed counsel.” Brown v. Child.’s Nat’l Med. Ctr., 773

F. Supp. 2d 125, 140 (D.D.C. 2011) (citation modified). In deciding whether to appoint counsel

for a pro se litigant proceeding in forma pauperis, the Court considers, among other factors, the

“[p]otential merit of the pro se party’s claims.” Local Civil Rule 83.11(b)(3)(ii). Given the

deficiencies in subject matter jurisdiction outlined above—and, in particular, the fact that

Carruthers’s claims appear to fall within the FTCA’s exception for intentional torts—the Court

concludes that it is not appropriate to appoint counsel in this case.

CONCLUSION

For the foregoing reasons, the Court grants the defendant’s Motion to Dismiss, Dkt. 9. A

separate order consistent with this decision accompanies this memorandum opinion.

DABNEY L. FRIEDRICH

August 31, 2026 United States District Judge

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