United States v. Johnson

1987-05-18
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Headline: Court upholds rule barring military families from suing the United States under the Federal Tort Claims Act for service‑related deaths, blocking claims even when civilian federal employees are accused.

Holding: The Court reaffirmed that Feres bars FTCA suits for injuries arising out of or in the course of activity incident to military service, so families cannot recover from the United States even when civilian federal employees are blamed.

Real World Impact:
  • Blocks families from suing the United States for service‑related deaths despite alleged civilian agency negligence.
  • Leaves survivors limited to veterans’ benefits and life insurance instead of FTCA compensation.
  • Reinforces military discipline rationale, discouraging civilian‑court review of service‑related actions.
Topics: military injuries, Federal Tort Claims Act, veterans' benefits, government liability, civilian agency negligence

Summary

Background

A Coast Guard helicopter pilot on a night rescue mission asked the Federal Aviation Administration (FAA), a civilian federal agency, for radar help. The FAA assumed radar control and the helicopter soon crashed into a mountain on Molokai, killing the pilot and all crew. The pilot's wife received veterans' benefits and life‑insurance payments, then sued the United States under the Federal Tort Claims Act (FTCA), alleging FAA negligence. A federal trial court dismissed the suit under the Court's earlier Feres rule; the Court of Appeals allowed the suit, and the Supreme Court agreed to decide the question.

Reasoning

The Court reaffirmed Feres and ruled that families cannot bring FTCA suits for injuries or deaths that arise out of or are in the course of activity incident to military service. The majority said three practical reasons support the rule: the armed forces relationship is uniquely federal, veterans' benefits provide a separate compensation scheme, and permitting these suits risks entangling civilian courts in matters that could harm military discipline. The Court rejected the idea that the rule should change simply because the alleged careless actor was a civilian federal employee.

Real world impact

The decision prevents survivors of service members killed or injured while performing military duties from suing the United States under the FTCA, even when federal civilian employees are blamed. Survivors remain eligible for veterans' benefits and insurance but cannot seek FTCA money damages from the Government for service‑incident harms. The case was sent back to the lower court to proceed consistent with the opinion.

Dissents or concurrances

A four‑Justice dissent argued Feres was wrongly decided and that the FTCA's clear text allows suits by servicemembers; the dissent would not extend Feres to bar suits against civilian federal employees.

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