Article By Ian Wallach Discussing Inmate's Rights and How To Frame A FTCA Complaint Published On Website For California Lawyer (A Division Of The Daily Journal). The article -- Federal Tort Claims & The Issue Of Sovereign Immunity, discusses the 9th Circuit' recent May 20, 2016 Opinion in Edison v. United States, ___ F.3d ___ (9th Cir. 2016), 2016 WL 2946347 (9th Cir.), where the Court enumerated the limits on the application of the "independent contractor" exception in cases where the USA has hired subcontractors to perform governmental duties but retained some responsibilities. It appears on the California Lawyer Website (www.callawyer.com) and be read here.