United States v. Muniz

Henry Winston (plaintiff) was incarcerated in a federal prison in Indiana. A prison medical officer misdiagnosed Winston, missing a brain tumor for many months. Ultimately, Winston’s attorney had him evaluated by an outside doctor and correctly diagnosed. However, Winston lost his eyesight during the tumor-removal process, and he claimed that his blindness was due to the delay caused by the federal prison’s misdiagnosis. Separately, Carlos Muniz (plaintiff) was incarcerated in a federal prison in Connecticut. Muniz was attacked by 12 other prisoners and chased into a dormitory. A prison guard locked the door to contain the incident rather than protecting Muniz. Muniz was beaten so severely that he suffered significant, long-term neurological issues. Muniz claimed that his injuries were caused by the federal prison’s failure to provide adequate prison guards and effective prisoner-security measures. Winston and Muniz each sued the United States government (defendant) under the Federal Torts Claims Act (FTCA), alleging that the federal government’s negligence made it responsible for their injuries. The government moved to dismiss both claims on the grounds that the FTCA did not allow lawsuits brought by prisoners. The district court granted the motion and dismissed both claims. The United States Court of Appeals for the Second Circuit reversed this ruling, finding that the FTCA did allow lawsuits by prisoners. The United States Supreme Court granted certiorari.