Is a claim for misrepresentation, fraud or deceit barred by sovereign immunity?

MultiRegion, United States of America

The following excerpt is from Salem v. Fed. Deposit Ins. Corp., Case No.: 15-CV-1114-AJB-BGS (S.D. Cal. 2016):

The reach of this exception is broad, applying to claims that sound in misrepresentation, fraud, or deceit, even when labeled otherwise. See United States v. Neustadt, 366 U.S. 696, 706-07 (1961) (finding negligence claim fell within misrepresentation exception, and thus barred by sovereign immunity, where it was predicated on negligent misrepresentation); Alexander v. United States, 787 F.2d 1349, 1350-51 (9th Cir. 1986) ("Although his claim is based on negligence, it is actually a claim for 'misrepresentation' and therefore barred by the immunity retained under 28 U.S.C. 2680(h).").

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