Case Explained: 25-2157: SHAHEED v. US [OPINION], Nonprecedential

Court: United States Court of Appeals for the Federal Circuit

Filed: 2026-07-13

The Federal Circuit affirmed the United States Court of Federal Claims’ dismissal of Plaintiff-Appellant Salahudin Shaheed’s breach of bailment contract claim against the United States. The court held that Shaheed failed to plausibly allege the existence of a valid contract because he did not demonstrate that he voluntarily delivered personal property (forty computer discs) to the Bureau of Prisons, nor did he allege that consideration was exchanged. The court applied the standard for express or implied-in-fact contracts with the government, which requires proof of mutuality of intent, consideration, an unambiguous offer and acceptance, and actual authority on the part of the government representative to bind the government. Citing *Kam-Almaz v. United States*, the court reiterated that a bailment relationship arises only when an owner voluntarily delivers personalty for a particular purpose; a purely unilateral act of seizing property does not evidence intent to enter into a bailment contract. The court found that Shaheed’s complaint alleged the government intercepted and seized the discs rather than receiving them through voluntary delivery, thereby negating the element of consideration. Additionally, the court rejected Shaheed’s argument that a signed “Rules Document” constituted a contract, ruling it was merely a unilateral agreement by the inmate to abide by facility rules without any corresponding consideration offered by the government. As a result of this affirmation, the dismissal of Shaheed’s claim for damages remains in effect, and no relief is granted on appeal. The case concludes with an order that no costs are awarded.

Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.