Juan José Lantigua-Núñez, a Dominican Republic citizen, was injured when U.S. Coast Guard agents fired live rounds at a vessel he was operating in international waters off the coast of Puerto Rico. Two rounds struck him, causing serious and permanent injuries to his left arm. Lantigua-Núñez filed a lawsuit under the Federal Tort Claims Act (FTCA), alleging that the Coast Guard used unlawful force in violation of the Fourth and Fourteenth Amendments. The district court dismissed the case, ruling that the claim sounded in admiralty and was therefore exclusively governed by the Suits in Admiralty Act (SIAA). When Lantigua-Núñez sought to amend his complaint to assert a claim under the SIAA, the court denied the request because the SIAA's two-year statute of limitations had expired. The case was dismissed with prejudice.
The First Circuit affirmed the dismissal, focusing on the statutory interplay between the FTCA and the SIAA. The court explained that while the FTCA's law enforcement proviso allows suits for intentional torts by federal law enforcement, it contains an express exclusion for claims where a remedy is provided by the SIAA. The court held that the SIAA provides an exclusive remedy for intentional maritime torts against the United States. To determine if the SIAA applies, the court applied the two-part test for admiralty jurisdiction: location and connection. The location element was satisfied because the incident occurred on navigable water. The connection element was met because the Coast Guard's actions bore a significant relationship to traditional maritime activity, such as patrolling and enforcing laws on the water. The court rejected the plaintiff's argument that the aerial nature of the attack removed it from maritime jurisdiction, noting that the plaintiff's attempt to ignore the involvement of water vessels constituted the 'hypergeneralization' warned against by the Supreme Court. Since the claim fell under the SIAA, the FTCA was unavailable. The court further addressed the plaintiff's argument that the SIAA provided no remedy because the claim was time-barred. The court ruled that the plaintiff cannot use the expiration of the statute of limitations to argue that the SIAA does not apply; the SIAA's exclusivity remains in force regardless of the plaintiff's failure to file timely.
The decision leaves the plaintiff without a judicial remedy for his injuries in federal court because the only available statute, the SIAA, has a two-year statute of limitations that has already expired. The ruling reinforces the principle that the SIAA is the exclusive vehicle for maritime torts against the government, preventing plaintiffs from using the FTCA as a backdoor when the SIAA is time-barred. The case remains dismissed with prejudice.
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