A federal court has dismissed a negligence claim against the United States Department of Agriculture (USDA) related to an incident where a contractor struck a man with a motorized cart. The ruling, issued by Magistrate Judge Zia M. Faruqui on June 30, 2026, affects the plaintiff, Ali Afkhami, and raises questions about the liability of federal contractors under the Federal Tort Claims Act (FTCA).
The case, Afkhami v. United States of America, Civil Action No. 2022-2818, centers on an incident that occurred on October 24, 2019, when USDA contractor Elroy Lewis Dennis accidentally hit Afkhami with a motorized cart while performing maintenance duties. Following the incident, Afkhami sought to hold both Dennis and the USDA liable for negligence, arguing that they breached their duty of care.
The USDA responded by filing a motion to dismiss the case, claiming it was protected by sovereign immunity, which shields the federal government from being sued without its consent. The court's decision to grant the USDA's motion to dismiss underscores the complexities of tort claims against federal entities and their contractors.
Ali Afkhami is the plaintiff in this case, while the USDA and its contractor, CMI Management Inc., are the defendants. The dispute arose after Afkhami was struck by Dennis, who was employed by CMI under a contract with the USDA. The USDA had entered into a contract with CMI to provide locksmithing services, which included hiring qualified personnel like Dennis. Although CMI managed Dennis's day-to-day activities, the USDA retained the authority to approve his hiring and oversee his work.
The case reached the District Court for the District of Columbia after Afkhami filed his complaint on September 16, 2022. He alleged negligence on the part of both Dennis and the USDA, claiming that their actions led to his injuries. The USDA countered that the claim was barred by sovereign immunity, arguing that Dennis, as a contractor, was not considered a government employee under the FTCA.
In the ruling, Judge Faruqui concluded that the USDA's motion to dismiss was valid. The court stated, "The independent contractor exception applies here, as the USDA did not exercise sufficient control over Dennis's work to establish liability." This determination was based on the level of control the USDA had over Dennis's daily operations and the nature of the contract between the USDA and CMI.
The court found that the USDA's involvement did not amount to direct supervision of Dennis's work. Instead, the USDA's role was limited to assigning tasks and monitoring their completion, which does not constitute the level of control necessary to overcome the independent contractor exception to sovereign immunity. The ruling emphasized that the USDA provided Dennis with tools and equipment but did not dictate how he performed his tasks.
The impact of this ruling extends beyond this individual case. It clarifies the boundaries of liability for the federal government when it comes to actions taken by independent contractors. The decision reinforces the principle that contractors are generally not considered employees of the government, and thus the government cannot be held liable for their actions unless it exercises substantial control over their work.
This ruling may influence future cases involving negligence claims against federal contractors. Plaintiffs seeking to hold the government accountable for the actions of its contractors may face significant challenges, particularly in demonstrating that the government had sufficient control over the contractor's operations.
Looking ahead, it is unclear whether Afkhami intends to appeal the court's decision. The ruling effectively dismisses his claims against the USDA with prejudice, meaning he cannot bring the same claims again in the future. There are no indications in the court filing regarding any related cases or further legal actions pending at this time.