CA8: TSA’s officers “satisfy the FTCA’s definition of an investigative or law enforcement officer” for FTCA

“The central question here is whether Transportation Security Administration (TSA) screening personnel, known as Transportation Security Officers (TSOs), satisfy the FTCA’s definition of an investigative or law enforcement officer. Holding that they do, we reverse and remand.” “Two of our sister circuits have addressed it but are divided on the answer. See generally Pellegrino v. U.S. Trans. Sec. Admin., 937 F.3d 164, 180 (3d Cir. 2019) (en banc) (finding that TSOs constitute investigative or law enforcement officers); Corbett v. Transp. Sec. Admin., 568 F. App’x 690, 701 (11th Cir. 2014) (per curiam) (finding that TSOs do not constitute investigative or law enforcement officers). Most recently, the Third Circuit, sitting en banc, found that TSOs satisfy the proviso’s definition. See Pellegrino, 937 F.3d at 180.” Iverson v. United States, 2020 U.S. App. LEXIS 27634 (8th Cir. Aug. 31, 2020).*

321 Fifth had four doors and appeared to be one address. It was actually three. Defendant disclaimed control of the unit where the grow operation was. He lacked standing to challenge it, but, even if he did, the warrant was with probable cause and the good faith exception applied. United States v. Rice, 2020 U.S. App. LEXIS 27638 (3d Cir. Aug. 31, 2020).*