Feb. 4, 2013, United States District Court for the Eastern District of California Holds That There Are No Pre-Filing Administrative Law Requirements For Tort Claims Brought Against Private Government Subcontractors.

In two valley fever actions pending in the EDCA, defendants the GEO Group, Inc. and Management & Training Corporation — who purportedly subcontracted to operate a federal detention facility — moved to dismiss the plaintiffs’ claims asserting that the plaintiffs had not properly exhausted administrative remedies prior to bringing suit (an argument frequently asserted by the USA and other sovereigns). The Court disagreed, holding that such private entities could not implement their own pre-suit filing requirements.  To read the order, click here.