Ifediba v. United States

Dr. Emmanuel Ifediba, an Alabama-based physician, was indicted in 2019 on federal healthcare fraud charges but was fully acquitted in 2021. He subsequently filed suit against the United States under the Federal Tort Claims Act (FTCA), alleging malicious prosecution, abuse of process, and constitutional violations by federal prosecutors. The U.S. District Court dismissed the claim for lack of subject matter jurisdiction, citing the discretionary function exception. On November 14, 2025, the U.S. Court of Appeals for the Eleventh Circuit affirmed the dismissal, holding that decisions to initiate and pursue a criminal prosecution are fundamentally discretionary in nature and thus shielded from liability under the FTCA.

The Eleventh Circuit Court of Appeals affirmed the dismissal, ruling that prosecutorial actions are grounded in policy judgment and fall squarely within the FTCA's discretionary function exception, barring Dr. Ifediba's malicious prosecution lawsuit.

Whether the discretionary function exception to the Federal Tort Claims Act immunizes the federal government from tort claims arising out of prosecutorial charging decisions and trial conduct.

The ruling reinforces the expansive protection afforded to federal prosecutors and the significant barriers faced by acquitted defendants seeking civil redress. While celebrated by law enforcement as necessary to preserve independent prosecutorial discretion, the decision has drawn sharp criticism from civil liberties advocates, who argue it leaves individuals without a meaningful remedy for abusive prosecutions.