Bryant v. United States of America

On August 6, 2024, the U.S. District Court for the District of Montana dismissed a personal injury lawsuit filed by plaintiff James Bryant against the United States. The incident occurred in July 2022 when Bryant was severely gored by a bison while hiking in Yellowstone National Park. Bryant alleged that the National Park Service acted negligently by failing to install adequate warning signs and failing to enforce safe wildlife viewing distances. Seeking substantial damages under the Federal Tort Claims Act, he argued the park’s inaction directly led to his injuries. The court granted the government’s motion to dismiss, ruling that decisions regarding the placement and content of wildlife warnings fall under the discretionary function exception to the Federal Tort Claims Act, barring the claim.

The court dismissed the case with prejudice, holding that the government’s actions fell within the discretionary function exception to the Federal Tort Claims Act, and thus the United States retained sovereign immunity against the negligence claims.

Whether the National Park Service’s decisions on posting wildlife warning signs and implementing safety measures constitute protected discretionary functions, thereby exempting the United States from tort liability under the Federal Tort Claims Act’s sovereign immunity exception.

The ruling reignited public debate over the breadth of the discretionary function exception, with critics asserting it unjustly shields federal agencies from accountability for visitor safety in national parks. Legal analysts highlighted the decision as reinforcing a significant barrier for injured individuals seeking redress against the government, while park advocates called for legislative reform to ensure clearer safety mandates.