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).").
The above passage should not be considered legal advice. Reliable answers to complex legal questions require comprehensive research memos. To learn more visit www.alexi.com.