(2009) ("Because vicarious liability is inapplicable to Bivens and § 1983 suits, a plaintiff must plead that each Government-official defendant, through the official’s own individual actions, has violated the Constitution.”). Second, the United States has not consented to be sued for monetary damages based on constitutional violations. See FDIC v. Meyer, 510 U.S. 471, 476-78, 114 S.Ct. 996, 127 L.Ed.2d 308 (1994). Third, the Court would lack jurisdiction over any potential claim for damages under the Federal Tort Claims Act (“FTCA”) because there is no indication that plaintiff has exhausted his administrative remedies by "first presenting] the claim to the appropriate Federal agency....” 28 U.S.C. § 2675. See Simpkins v. District of Columbia Gov’t, 108 F.3d 366, 371 (D.C.Cir. 1997) (<HOLDING>). Moreover, because plaintiff was released from
recognizing that issue exhaustion is a mandatory although not jurisdictional requirement holding that exhaustion of issues is jurisdictional holding that issue exhaustion is mandatory even if not a statutory jurisdictional requirement holding that exhaustion is mandatory and jurisdictional holding that the ftcas exhaustion requirement is jurisdictional