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As noted in Henderson v. United States, 785 F.2d 121 (4th Cir. 1986), plaintiffs must satisfy certain prerequisites before filing a civil action under the FTCA. Id. at 123. 'The FTCA clearly provides that, prior to bringing an action against the United States in federal court, a claimant 'shall have first presented the claim to the appropriate Federal agency and his claim shall have been finally denied by the agency.'' Id. (quoting 28 U.S.C. § 2675(a)); see Plyler v. United States, 900 F.2d 41, 42 (4th Cir. 1990). Multiple plaintiffs must satisfy the jurisdictional requirements individually. Muth v. United States, 1 F.3d 246, 249 (4th Cir. 1993). Further, 'it is well-settled that the requirement of filing an administrative claim is jurisdictional and may not be waived.' Henderson, 785 F.2d at 123 (citing Kielwien v. United States, 540 F.2d 676, 679 (4th Cir.), cert. denied, 429 U.S. 979, 50 L. Ed. 2d 588, 97 S. Ct. 491 (1976)).
The Fourth Circuit strictly construes the FTCA's terms, which are prescribed by Congress as conditions of the federal government's limited waiver of sovereign immunity. Thigpen v. United States, 800 F.2d 393, 394 (4th Cir. 1986) ...
