Kwitek v. United States Postal Service
Edward Kwitek, a driver for Midwest Transport, Inc., sued the United States Postal Service (USPS) under the Federal Tort Claims Act (FTCA) for injuries sustained while loading mail at a post office, alleging negligence by USPS employees. The government moved to dismiss the complaint for lack of subject matter jurisdiction, asserting that Kwitek was an independent contractor and his injury resulted from a discretionary function, thereby making the FTCA's waiver of sovereign immunity inapplicable. The court denied the government's motion. It ruled that the independent contractor exception did not apply because the alleged negligence was on the part of USPS employees failing to perform their regular duties. Furthermore, the discretionary function exception was also inapplicable, as the alleged conduct was not policy-driven but rather a failure to follow established protocol. The case was then referred for a settlement conference.