After the United States Supreme Court created a right to sue for constitutional
violations - such as intentional torts - in the Bivens case, Congress amended
the FTCA to allow claims for assault, battery, false imprisonment, false arrest,
abuse of process, or malicious prosecution against an "investigative or law
enforcement officer" of the United States. An "investigative or law enforcement
officer" was defined as "...any officer of the United States who is empowered
by law to execute searches, to seize evidence, or to make arrests for violations
of Federal law.