5. (§21.7) Proper Defendant
It should be noted that the FTCA does not create a cause of action against individual federal employees but, rather, permits certain types of actions against the United States. Love v. United States, 656 F. Supp. 847 (D. Mont. 1987), rev’d and remanded on other grounds, 871 F.2d 1488 (9th Cir. 1989); Kaufmann v. United States, 840 F. Supp. 641 (E.D. Wis. 1993) (the court found that it had subject matter jurisdiction in a case involving an improper criminal prosecution for state law money...
