Case Explained: SHIRLEY BOATWRIGHT v. PAMELA VALDEZ

Court: United States Court of Appeals for the Fourth Circuit

Filed: 2026-07-10

The fourth-circuit affirmed the district court’s order dismissing Shirley Boatwright’s claim under the Federal Tort Claims Act (FTCA) for lack of subject matter jurisdiction due to her failure to exhaust administrative remedies. The court applied the standard that an FTCA plaintiff must exhaust all available administrative remedies within the relevant federal agency before filing suit, a prerequisite that is mandatory and cannot be waived by the court. Because the district court correctly determined that Boatwright had not satisfied this exhaustion requirement, the appellate court found no reversible error in the dismissal and affirmed the judgment without oral argument.

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