Chutzpah: After Criminal Prosecution Defendant Sues USA
Post 5164

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Dr. Segun Patrick Adeoye, a medical doctor, filed a lawsuit against the United States of America, seeking damages for alleged violations during his criminal prosecution. He was acquitted by a jury but claims to have suffered significant harm, including financial losses, damage to his professional reputation, and personal distress.

In Dr. Segun Patrick Adeoye v. The United States Of America, Civil Action No. 4:25-cv-83, United States District Court, E.D. Texas, Sherman Division (July 23, 2025) the USDC dismissed Adeoye’s suit.

FACTUAL BACKGROUND

Dr. Adeoye was indicted on charges of conspiracy to commit wire fraud and money laundering. The indictment alleged that he and his co-conspirators obtained at least seventeen million dollars through various fraudulent schemes. Despite being acquitted, Dr. Adeoye claims that his prosecution caused him ongoing harm.

PROCEDURAL BACKGROUND

Dr. Adeoye’s complaint asserts three causes of action:

1. Violation of Due Process: Adeoye claims his due process rights were violated due to wrongful detention, lack of legal safeguards, and delays in his trial.

2. Violation of the Speedy Trial Act: Adeoye alleges unnecessary procedural delays caused by the government’s failure to advance the case.

3. Negligence: Adeoye asserts that the government was negligent in investigating the charges, delaying access to legal counsel, and not advancing the case in a reasonable time frame.

ANALYSIS

The court’s analysis focused on the government’s motion to dismiss, arguing that Dr. Adeoye’s claims were barred by sovereign immunity. The court agreed with the government, stating that the United States had not consented to being sued for the type of constitutional tort claims Dr. Adeoye seeks. The court also found that Dr. Adeoye’s claims under the Speedy Trial Act and negligence are not cognizable under the Federal Tort Claims Act (FTCA) due to lack of exhaustion of administrative remedies.

A Rule 12(b)(6) motion allows a party to move for dismissal of an action when the complaint fails to state a claim upon which relief can be granted. When considering a motion to dismiss under Rule 12(b)(6), the Court must accept as true all well-pleaded facts in the plaintiff’s complaint and view those facts in the light most favorable to the plaintiff. The Court may consider the complaint, any documents attached to the complaint, and any documents attached to the motion to dismiss that are central to the claim and referenced by the complaint. The Court must then determine whether the complaint states a claim for relief that is plausible on its face.

The Government argues that Rule 12(b)(1) bars Plaintiff’s claims. That is because, according to the Government, each of Plaintiff’s claims are barred under sovereign immunity. Before the Court can proceed any further, it must ensure that sovereign immunity does not prevent it from presiding over the case.

Because Plaintiff’s Complaint seeks to assert a claim under the civil rights statutes and the United States has not consented to suits for such claims, Plaintiff’s claim here is barred by sovereign immunity.

Fundamentally, Plaintiff’s Complaint is also deficient because it mentioned no individual connected to the conduct complained of at all.

Plaintiff’s Speedy Trial Act Claim

The only remedy for a violation of the STA is dismissal of an indictment. Plaintiff’s Complaint does not present any theory of recovery under the STA that would allow the Court to engage with it any further. Plaintiff has not carried his burden here. He has not even attempted to demonstrate that his STA cause of action is in exact compliance with the terms of a statute under which the sovereign has consented to be sued. Thus, Plaintiff’s STA claim must be dismissed.

Even if sovereign immunity did not apply, the Court would nonetheless dismiss each of Plaintiff’s claims under Rule 12(b)(6). Plaintiff’s Complaint is wholly deficient and borders on frivolous.

CONCLUSION

The court granted the United States’ motion to dismiss, dismissing Dr. Adeoye’s § 1983 and Speedy Trial Act claims with prejudice and his FTCA claim without prejudice.

ZALMA OPINION

Health insurance fraud is a serious crime. Dr. Adeoye was indicted as part of a multi-million dollar fraud scheme. The case went to trial and Dr. Adeoye was acquitted because the USA failed to convince the jury of his crimes beyond a reasonable doubt. Dr. Adeoye sued the government without first presenting the claim and without complying with the tort claims act resulting in the government’s motion to dismiss the suit based on sovereign immunity.

(c) 2025 Barry Zalma & ClaimSchool, Inc.

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