Ninth Circuit -- JUAN VALADEZ LOPEZ V. UNITED STATES OF AMERICA

Where plaintiff doesn't name the US on initial complaint, subsequently exhausts administrative remedy and then amends the complaint to add the US, exhaustion is kosher, there's no need to file a new action, and the amended complaint does not relate back to original filing for purposes of assessing exhaustion.

Claim not within FTCA waiver of sovereign immunity, as no specific negligent federal conduct alleged in pleadings.

No error in dismissal of S1983 & Monell claims.

JUAN VALADEZ LOPEZ V. UNITED STATES OF AMERICA