11th Cir: TSA Officers Potentially Liable Under FTCA

TSA employees are a hot topic due to the DHS shutdown. Recently, the Eleventh Circuit weighed in on a separate TSA issue, joining mulitple federal circuits in holding that TSA officers are potentially liable for intentional torts. Koletas v. United States, 159 F.4th 813, 830 (11th Cir. 2025) (“The law enforcement proviso waives sovereign immunity for certain intentional torts—including those alleged by [plaintiff][battery, false imprisonment, and IIED]—committed by United States officers who execute searches for violations of federal law. TSOs fall within that statutory definition.”).