A U.S. District Court in Washington, D.C., has dismissed a lawsuit filed by Tracey Burroughs Travers against the United States. The case, Civil Action No. 2025-2996, involved allegations of defamation and wrongful termination related to her employment at the Smithsonian Institution. The court's decision highlights the complexities of suing the federal government, particularly under the Federal Tort Claims Act (FTCA).

The court ruled on November 9, 2026, granting the government's motion to dismiss the case. This ruling is significant as it underscores the legal barriers individuals face when seeking redress against federal entities.

Background

Tracey Burroughs Travers was employed by the Smithsonian Institution when she had a meeting with her supervisor, Morgan C. Kane, on October 28, 2024. During this meeting, Kane allegedly stated that Travers smelled of alcohol and did not want to continue the discussion. Following this incident, Travers claimed she was fired and accused Kane of lying about her.

On June 5, 2025, Travers filed a civil action in the Superior Court of the District of Columbia. The United States government removed the case to federal court on September 3, 2025, asserting that Kane was acting within the scope of her employment at the time of the alleged incident. This led to the substitution of the United States as the defendant in the case, allowing Travers to proceed under the FTCA.

The Ruling

In her opinion, Judge Tanya S. Chutkan stated that the court must dismiss Travers' claims due to a lack of jurisdiction and failure to state a claim. The court found that Travers had not presented her claims to the appropriate federal agency before filing suit, which is a requirement under the FTCA.

The court ruled, "the complaint fails to state a defamation claim, and even if such claim were adequately alleged, the FTCA bars it."

Judge Chutkan explained that to establish a defamation claim, a plaintiff must show that the defendant made a false statement, published it to a third party, and that the statement caused harm. However, Travers did not provide sufficient evidence to support these elements. Additionally, the FTCA explicitly excludes defamation claims from its waiver of sovereign immunity, rendering her claim against the government invalid.

Impact

This ruling has significant implications for individuals seeking to hold the federal government accountable for alleged misconduct by its employees. The court's decision reinforces the importance of following procedural requirements when filing claims under the FTCA. It serves as a reminder that failure to comply with these rules can lead to the dismissal of a case, regardless of the merits of the underlying claims.

Furthermore, the court's dismissal of Travers' wrongful termination claim highlights the challenges employees face when alleging discrimination or wrongful termination in federal employment. Without specific allegations of unlawful termination, such as discrimination based on race or gender, claims may not proceed in federal court.

What's Next

Travers has the option to appeal the court's decision. However, the ruling sets a high bar for any future claims she may wish to pursue against the United States. There are no indications of related cases pending in the court system at this time.