Will v. Hallock

Federal authorities seized Susan Hallock’s (plaintiff) computer equipment, software, and disk drives pursuant to a warrant. In the process, several disk drives were ruined and all of Hallock’s stored data, including trade secrets and account files for her business, was lost, forcing Hallock out of business. Hallock brought suit against the government under the Federal Tort Claims Act (FTCA), claiming negligence on the part of the federal authorities that seized her property. While that suit was still pending, Hallock filed a separate suit against Will, et al., the individual federal agents (defendants). The district court dismissed Hallock’s FTCA suit, finding an exception to the waiver of sovereign immunity. The defendants then moved for judgment in this suit, citing the judgment bar in the FTCA, which stated that any judgment on an FTCA claim based on sovereign immunity was a complete bar to any action coming about under the same subject matter against the government employees whose conduct gave rise to the FTCA claim. The district court denied the defendants’ motion, refusing to apply the judgment bar because the dismissal of Hallock’s FTCA claim was on procedural grounds. The defendants appealed and the court of appeals agreed to hear the appeal under the collateral order doctrine. The United States Supreme Court granted certiorari to determine whether the court of appeals had the jurisdiction to hear the appeal.