Timothy Taylor v. US

Circuit 4Aug 11, 2026

Split Score

SplitScore: 81/100

Case Summary

Disposition

Affirmed

Timothy Dashaun Taylor sued the United States under the Federal Tort Claims Act, alleging that FBI agents knowingly pursued him for a kidnapping-murder he did not commit. The Fourth Circuit affirmed the district court’s dismissal, holding that Taylor forfeited any challenge to the discretionary-function-exception ground that deprived the court of subject-matter jurisdiction.

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Circuit Split Identified

Legal Issue

Whether the FTCA’s discretionary function exception shields federal officials when the challenged conduct is alleged to be unconstitutional.

Circuit Positions

Circuit 0Circuit 1Circuit 3Circuit 4(this circuit)Circuit 8Circuit 9

Unconstitutional conduct is not protected by the FTCA discretionary function exception.

Circuit 7Circuit 11

The discretionary function exception applies even to unconstitutional conduct.

Conflict Summary

Six circuits (including the Fourth) hold that federal officials have no discretion to commit unconstitutional acts, so such conduct falls outside the discretionary function exception; the Seventh and Eleventh Circuits conclude that the exception may still bar FTCA claims even when the alleged conduct violates the Constitution.

Parties & Counsel

Parties

Appellant:Timothy Dashaun Taylor
Appellee:United States of America

Legal Counsel

Appellant:Matthew Ryan McKaig, MCKAIG LAW FIRM LLC
Appellee:Kimberly Varadi Hamlett, OFFICE OF THE UNITED STATES ATTORNEY