In Rayonier, infra, this c ourt held that the Federal tort c laims Act (F tcA) "makes the u nited States liable ( with certain exceptions which are not relevant here ) for the negligence of its employees" in responding to wildland fire, ruling that none of the FTCA statutory exceptions apply in this context. ( emphasis added). Yet, four subsequent c ircuit c ourts of Appeals have all held that the F tcA "discretionary function exception" bars liability for negligent wildland fire response, contrary to Rayonier . Given the conflict, is the United States liable for the negligence of its wildland fire managers?

Is the United States liable for the negligence of its wildland fire managers?