28 U.S.C. § 2676
Section 2676 · Judgment as bar
Amended 1 time on record
Applied in 104 court decisions — leading case Will v. Hallock (2006)
Most recently applied in Justin Longworth v. A. Mansukhani (April 2025)
Cases citing this section usually also cite 28 U.S.C. § 1346 · 28 U.S.C. § 2680 · 28 U.S.C. § 2679
How often courts cite this section
Court decisions citing this, by year.Markers show enactment, consequential amendments, and circuit splits over this section — watch for a citation surge after a change or a disagreement. The dip in the last several years is a data-coverage gap, not a real trend — our corpus holds fewer opinions from the most recent years, so recent citations are undercounted.
The judgment in an action under section 1346 (b) of this title shall constitute a complete bar to any action by the claimant, by reason of the same subject matter, against the employee of the government whose act or omission gave rise to the claim.
Editorial notes U.S. Code · Office of the Law Revision Counsel
Historical and Revision Notes
Based on title 28, U.S.C., 1940 ed., §931(b) (Aug. 2, 1946, ch. 753, §410(b), 60 Stat. 844).
Section constitutes the first sentence of section 931(b) of title 28, U.S.C., 1940 ed. Other provisions of such section 931(b) are incorporated in section 2675 of this title.
Changes were made in phraseology.
Senate Revision Amendment
This section was eliminated by Senate amendment. See 80th Congress Senate Report No. 1559.