The Eleventh Circuit Court of Appeals vacated a federal district court's dismissal of negligence claims filed by three families against the United States government after their children suffered physical and emotional abuse at a government-owned childcare facility.
In *John Doe, 1 v. United States* (11th Cir. 2026), a three-judge panel led by Circuit Judge Jill Pryor reversed the U.S. District Court for the Middle District of Georgia's decision to dismiss the case based on sovereign immunity protections. The district court had concluded that the Federal Tort Claims Act's intentional tort exception barred the families' negligence claims.
The case involves three minor children who were harmed by two employees at a government-operated childcare center. Their parents filed suit on behalf of the children, alleging that the United States was negligent in failing to protect the minors from abuse while in federal care.
The families' lawsuit centers on allegations that government employees physically and emotionally abused the children while they were enrolled at the federal childcare facility. The parents brought negligence claims against the United States, arguing that the government failed in its duty to protect children under its care and supervision.
The district court initially dismissed all claims, finding that it lacked subject matter jurisdiction under the Federal Tort Claims Act. The lower court ruled that because the underlying conduct involved intentional acts by government employees, the claims fell within the FTCA's intentional tort exception found in 28 U.S.C. § 2680(h), which preserves the government's sovereign immunity for certain intentional wrongdoing by federal employees.
The FTCA generally waives the federal government's sovereign immunity for tort claims arising from negligent acts by government employees acting within the scope of their employment. However, the law contains several exceptions that restore immunity, including for claims arising from assault, battery, and other intentional torts committed by federal workers.
The district court also denied the families' motion to amend their complaint, determining that any proposed amendments would be futile given the court's jurisdictional ruling. This procedural decision prevented the parents from potentially reformulating their claims to avoid the intentional tort exception.
The Eleventh Circuit's decision to vacate the dismissal suggests the appeals court disagreed with the district court's analysis of how the FTCA's intentional tort exception applies to negligence claims. The distinction is crucial because it determines whether families can hold the federal government accountable for failing to protect children from abuse, even when that abuse is committed by government employees acting intentionally.
The case highlights ongoing legal challenges around government liability for contractor and employee misconduct at federal facilities. When government workers commit intentional acts of abuse, courts must determine whether claims against the government for negligent supervision or failure to protect fall within the FTCA's waiver of immunity or are barred by the intentional tort exception.
Legal experts note that the Eleventh Circuit's decision could have broader implications for similar cases involving alleged government negligence in protecting vulnerable populations from intentional harm by federal employees or contractors. The ruling may provide a pathway for families to seek accountability when government institutions fail to safeguard those in their care.
The families were represented in their appeal after the district court's adverse ruling. The case was argued before a panel consisting of Circuit Judges Jill Pryor, Andrew Brasher, and Barbara Lagoa, with Judge Pryor writing the majority opinion.
The government will now face renewed litigation in the district court, where the families can proceed with their negligence claims. The case may also prompt the government to seek further appellate review, though no such motion has been filed yet.
For the three families involved, the Eleventh Circuit's decision represents a significant procedural victory that allows their claims to move forward. However, they will still need to prove their allegations that the government was negligent in protecting their children and that such negligence caused compensable harm.
The case underscores the complex legal framework governing when citizens can sue the federal government for injuries caused by government employees. While the FTCA provides a general waiver of sovereign immunity, its various exceptions create ongoing litigation over the scope of government accountability for employee misconduct.
The opinion was designated for publication, meaning it will serve as binding precedent within the Eleventh Circuit's jurisdiction, which covers Alabama, Florida, and Georgia. This precedential value may influence how similar cases involving alleged government negligence in protecting individuals from intentional harm are resolved in federal courts.