Burchfield v. United States, 168 F.3d 1252 (11th Cir. 1999). · Go Syfert
Burchfield v. United States, 168 F.3d 1252 (11th Cir. 1999). Cases Citing This Book View Copy Cite
129 citation events (107 in the last 25 years) across 25 distinct courts.
Strongest positive: Rocky Freeman v. J. Lincalis (ca3, 2025-10-29)
Treatment trajectory · 1999 → 2026 · click a year to view as-of
1999 2012 2026
Top citers, strongest first. 45 distinct citers. How cited ↗
examined Cited as authority (verbatim quote) Rocky Freeman v. J. Lincalis (3×) also: Cited as authority (rule), Cited "see, e.g."
3rd Cir. · 2025 · quote attribution · 1 verbatim quote · confidence high
we do not require the claimant to provide the agency with a preview of his or her lawsuit by reciting . . . every factual detail that might be relevant
examined Cited as authority (verbatim quote) Dixon v. United States (6×) also: Cited "see", Cited "see, e.g."
S.D. Ga. · 2015 · signal: see · quote attribution · 3 verbatim quotes · confidence high
nor does our interpretation of the statute mean that an agency will be on notice of all the facts contained in voluminous records presented by a claimant, if the claimant has not pointed to specific sources of injury.
discussed Cited as authority (rule) Jessica Hernandez v. United States
11th Cir. · 2026 · confidence medium
The presentation requirement is meant to “giv[e] agencies an opportunity to settle suits before liti- gation commence[s],” which in turn can “ease court congestion and avoid unnecessary litigation, while making it possible for the Government to expedite the fair settlement of tort claims asserted against the United States.” Burchfield v. United States, 168 F.3d 1252, 1255 (11th Cir. 1999) (citation modified).
discussed Cited as authority (rule) Angelo Jacob Fermo v. U.S. Department of Homeland Security
S.D. Ala. · 2026 · confidence medium
Ala. 2014) (quoting Burchfield v. United States, 168 F.3d 1252, 1255 (11th Cir. 1999) (quoting Adams v. United States, 615 F.2d 284, 289 (5th Cir. 1980), decision clarified on denial of reh'g, 622 F.2d 197 (5th Cir. 1980))).
cited Cited as authority (rule) Vincent v. United States
M.D. Fla. · 2025 · confidence medium
Burchfield v. United States, 168 F.3d 1252, 1255 (11th Cir. 1999) (internal quotation marks and citation omitted); see also Free v. United States, 885 F.2d 840, 842 (11th Cir. 1989) (same).
discussed Cited as authority (rule) Yarullina v. United States of America
D.D.C. · 2025 · confidence medium
An agency is constructively on notice of any “theories of recovery that its reasonable investigation of the specific allegations of the claim should reveal.” Burchfield v. United States, 168 F.3d 1252, 1255 (11th Cir. 1999).
cited Cited as authority (rule) Taylor v. United States
D.S.C. · 2024 · confidence medium
“In short, the amount of information required is minimal.” Id. (quoting Burchfield v. United States, 168 F.3d 1252, 1255 (11th Cir. 1999) (internal quotation marks omitted)).
cited Cited as authority (rule) Taylor v. United States
D.S.C. · 2024 · confidence medium
“In short, the amount of information required is minimal.” Id. (quoting Burchfield v. United States, 168 F.3d 1252, 1255 (11th Cir. 1999) (internal quotation marks omitted)).
cited Cited as authority (rule) Smith v. United States
W.D. Va. · 2024 · confidence medium
Va. Aug. 30, 2016) (quoting Burchfield v. United States, 168 F.3d 1252, 1256-57 (11th Cir. 1999)).
discussed Cited as authority (rule) Mitchell v. HUD and Prichard Housing Authority
S.D. Ala. · 2024 · confidence medium
It is well- settled that “[a] district court only has jurisdiction over a FTCA action if the plaintiff has met section 2675(a)’s requirements.” Burchfield v. United States, 168 F.3d 1252, 1254-55 (11th Cir. 1999) (citing Bush v. United States, 703 F.2d 491, 494 (11th Cir. 1983)).
cited Cited as authority (rule) John Jones v. United States
11th Cir. · 2024 · confidence medium
Burchfield v. United States, 168 F.3d 1252, 1255 (11th Cir. 1999).
discussed Cited as authority (rule) Dodd v. United States
M.D. Fla. · 2022 · confidence medium
Unlike the claim in Tidd, Dodd’s claim was not “so vague or lacking in detail that the agency [could] not be expected to initiate any investigation at all.” Burchfield v. United States, 168 F.3d 1252, 1257 (11th Cir. 1999).
cited Cited as authority (rule) Wellman v. Centers for Disease Control and Prevention (MAG+)
M.D. Ala. · 2022 · confidence medium
An agency’s failure to dispose of a claim within six months is deemed to be a final denial.” Burchfield v. United States, 168 F.3d 1252, 1254 (11th Cir. 1999) (citing 28 U.S.C. § 2675 (a)).
discussed Cited as authority (rule) Lamb v. Bureau of Alcohol, Tobacco, Firearms and Explosives
D.D.C. · 2022 · confidence medium
And for the reasons explained above, it concludes that Lamb’s submission to DHS did not exhaust those claims. 12 expected to initiate any investigation at all.” Burchfield v. United States, 168 F.3d 1252, 1257 (11th Cir. 1999); see also Tidd v. United States, 786 F.2d 1565, 1568 (11th Cir. 1986) (“For an agency to be able to initiate an investigation into a tort claim . . . it must be apprised of the location and approximate date of the incident.”); Romulus v. United States, 160 F.3d 131, 132 (2d Cir. 1998) (“A claimant must provide more than conclusory statements which afford the ag…
discussed Cited as authority (rule) Horne v. Talladega FBOP FCI
N.D. Ala. · 2021 · confidence medium
“A plaintiff bringing a claim against the United States under the FTCA must first present the claim to the appropriate federal agency and wait for the agency to finally deny it.” Burchfield v. United States, 168 F.3d 1252, 1254 (11th Cir. 1999) (citing 28 U.S.C. § 2675 (a)).
discussed Cited as authority (rule) Kelly Copen v. United States
6th Cir. · 2021 · confidence medium
Federal courts have noted that Congress did not intend for the procedural requirements in the FTCA “to place procedural hurdles before potential litigants” but rather “to facilitate early dispositions of claims.” Burchfield v. United States, 168 F.3d 1252, 1255 (11th Cir. 1999) (citing Lopez v. United States, 758 F.2d 806, 809 (1st Cir. 1985) (“[I]ndividuals wishing to sue the government must comply with the details of [section 2675], but . . . the law was not intended to put up a barrier of technicalities to defeat their claims.”)).
discussed Cited as authority (rule) KNAPIK v. UNITED STATES OF DEPARTMENT OF VETERANS AFFAIRS
M.D. Ga. · 2020 · confidence medium
On November 19, 2018, the VA denied the claim. [Doc. 15-4].19 Subsequently, Plaintiffs filed this wrongful death action against the United States, through its agency, 19 “A plaintiff bringing a claim against the United States under the FTCA must first present the claim to the appropriate federal agency and wait for the agency to finally deny it.” Burchfield v. United States, 168 F.3d 1252, 1254 (11th Cir. 1999).
discussed Cited as authority (rule) Lebedinsky v. United States
S.D. Fla. · 2020 · confidence medium
“A district court lacks jurisdiction over a[] [Federal Tort Claims Act] action if the plaintiff has not complied with the notice requirements of § 2675(a).” Id. at 263-264 (citing Burchfield v. United States, 168 F.3d 1252, 1254-55 (11th Cir. 1999)).
discussed Cited as authority (rule) Pinson v. United States
M.D. Penn. · 2019 · confidence medium
The requisite written notice is “minimal,” and a claimant is required to provide “only enough information to allow the agency to ‘begin its own investigation’ of the alleged events and explore the possibility of settlement.” Burchfield v. United States, 168 F.3d 1252, 1255 (11th Cir. 1999) (quoting Adams v. United States, 615 F.2d 284, 289 (5th Cir. 1980)).
discussed Cited as authority (rule) Robert F. Dugan v. Warden, FCC Coleman - USP I (2×) also: Cited "see"
11th Cir. · 2016 · confidence medium
See 28 C.F.R. § 542.10 (c); Burchfield v. United States, 168 F.3d 1252, 1254 (11th Cir. 1999).
examined Cited as authority (rule) Gerald A. West v. C. Peoples (4×) also: Cited "see"
11th Cir. · 2014 · confidence medium
Burchfield v. United States, 168 F.3d 1252, 1255 (11th Cir.1999).
cited Cited as authority (rule) Mixon v. United States
M.D. Ga. · 2014 · confidence medium
Burchfield v. United States, 168 F.3d 1252, 1255 (11th Cir.1999).
discussed Cited as authority (rule) Richard S. Milbauer v. United States (2×)
11th Cir. · 2014 · confidence medium
Relying on our precedent in Burchfield v. United States, 168 F.3d 1252, 1255 (11th Cir.1999), he argued he was not required to provide the VA with every possible theory of recovery.
examined Cited as authority (rule) Bates v. United States Government (5×) also: Cited "see", Cited "see, e.g."
S.D. Ala. · 2014 · confidence medium
To sufficiently meet section 2675(a)’s requirement of giving notice to the appropriate federal agency, “a claimant must do two things: ‘(1) give [ ] the [appropriate] agency written notice of his or her claim sufficient to enable the agency to investigate and (2) placet] a value on his or her claim.’ ” Burchfield v. United States, 168 F.3d 1252, 1255 (11th Cir.1999) (quoting Adams v. United States, 615 F.2d 284, 289 (5th Cir.1980), decision clarified on denial of reh’g, 622 F.2d 197 (5th Cir.1980)).
discussed Cited as authority (rule) Bowling v. United States
D. Kan. · 2010 · confidence medium
Feb. 6, 2009) (noting that, under Sixth and Eleventh Circuit law, the administrative agency is deemed to be on notice of "the theories of recovery that its reasonable investigation of the specific allegations of the claim should reveal”) (quoting Burchfield v. United States, 168 F.3d 1252, 1255 (11th Cir.1999)). 23 .
cited Cited as authority (rule) Le v. Securities & Exchange Commission
N.D. Ga. · 2008 · confidence medium
Burchfield v. United States, 168 F.3d 1252, 1254-55 (11th Cir.1999).
cited Cited as authority (rule) Standifer v. Securities & Exchange Commission
N.D. Ga. · 2008 · confidence medium
Burchfield v. United States, 168 F.3d 1252, 1254-55 (11th Cir.1999).
discussed Cited as authority (rule) Ewin Oscar Martinez v. Leroy Minnis
11th Cir. · 2007 · confidence medium
Burchfield v. United States, 168 F.3d 1252, 1254-55 (11th Cir.1999); see also Barnett v. Okeechobee Hosp., 283 F.3d 1232, 1237-38 (11th Cir.2002) (“[T]he administrative notice requirement of 28 U.S.C. § 2675 ‘is jurisdictional and cannot be waived.’ ” (quoting Lykins v. Pointer Inc., 725 F.2d 645, 646 (11th Cir.1984))).
cited Cited as authority (rule) William Robinson v. United States
11th Cir. · 2007 · confidence medium
Burchfield v. United States, 168 F.3d 1252, 1254-55 (11th Cir.1999).
discussed Cited as authority (rule) Southern v. United States
W.D. Tex. · 2007 · confidence medium
The Court recognizes that the filing of an administrative claim alone does not “mean that an agency will be on notice of all facts contained in voluminous records presented by a claimant, if the claimant has not pointed to specific sources of injury.” Burchfield v. United States, 168 F.3d 1252, 1256-57 (11th Cir.1999).
discussed Cited as authority (rule) Leroy Ellis v. Bureau of Prisons
11th Cir. · 2007 · confidence medium
For a district court to have jurisdiction over an FTCA action, a plaintiff must first show that he presented his claim to the agency and that the agency denied it in writing. 28 U.S.C. § 2675 (a); Burchfield v. United States, 168 F.3d 1252, 1254-55 (11th Cir.1999).
discussed Cited as authority (rule) Keira v. United States Postal Inspection Service Ex Rel. Heath
11th Cir. · 2005 · confidence medium
To preserve his claim, a plaintiff “must first present the claim to the appropriate federal agency and wait for the agency to finally deny it.” Burchfield v. United States, 168 F.3d 1252, 1254 (11th Cir.1999).
discussed Cited as authority (rule) Langley v. United States
D. Haw. · 2002 · confidence medium
Citing Burchfield v. United States, 168 F.3d 1252, 1255 (11th Cir.1999), Langley argues that her new theories were part of her original claim to the Navy because the Navy’s “reasonable investigation” of her fall should have revealed the design defects.
examined Cited as authority (rule) Drew v. United States (3×)
4th Cir. · 2000 · confidence medium
In short, the amount of information required is "minimal." Burchfield v. United States, 168 F.3d 1252, 1255 (11th Cir. 1999) (citations omitted).
examined Cited as authority (rule) Sterling Drew, a Minor Under the Age of Thirteen Years, by Guardian Ad Litem Martha Drew Martha Drew Jebediah Drew v. United States (7×)
4th Cir. · 2000 · confidence medium
In short, the amount of information required is "minimal." 57 Burchfield v. United States, 168 F.3d 1252, 1255 (11th Cir. 1999) (citations omitted).
examined Cited as authority (rule) Knight v. United States (4×) also: Cited "see"
M.D. Ala. · 1999 · confidence medium
In support of its Motion, the United States claims that, “[p]ur-suant to the provisions of 28 U.S.C. § 2679 (a), plaintiffs exclusive remedy for a tort is to sue the United States in compliance with the Federal Tort Claims Act, 28 U.S.C. §§ 1346 (b) and 2672-80.” (Mot. ¶ 4.) The United States argues that “plaintiffs failure to file an administrative claim under the FTCA [prior to the institution of this action] deprives this Court of subject matter jurisdiction.” (Id. ¶ 8.) The FTCA requires that “[a] plaintiff who sues under the Federal Tort Claims Act, 28 U.S.C. §§ 2671 et s…
discussed Cited as authority (rule) Young v. SouthTrust Bank, N.A.
M.D. Ala. · 1999 · confidence medium
The purpose of the notice required by Section 2675(a) is to give federal agencies “a fair opportunity to investigate and possibly settle ..-. claims.” Burchfield v. United States, 168 F.3d 1252, 1255 (11th Cir.1999).
examined Cited "see" Doe v. Baker County (3×) also: Cited "see, e.g."
M.D. Fla. · 2025 · signal: see · confidence high
See Burchfield, 168 F.3d at 1255 (explaining that an agency is not only on notice of the theories of recovery in the claim, but also any theories of recovery that a reasonable investigation of the allegations should reveal); see also Brown, 838 F.2d at 1160 (“The notice requirement does not require a claimant to enumerate each theory of liability in the claim”).
discussed Cited "see" Navarro-Martin v. United States Custom and Border Protection
M.D. Fla. · 2024 · signal: see · confidence high
See Burchfield v. United States, 168 F.3d 1252 , 1254–55 (11th Cir. 1999) (holding that a district court lacks jurisdiction over an FTCA action if the plaintiff has not complied with the notice requirements of § 2675(a)); Suarez v. United States, 22 F.3d 1064, 1065 (11th Cir. 1994) (“A federal court may not exercise jurisdiction over a suit under the FTCA unless the claimant first files an administrative claim with the appropriate agency.”); see also McAfee v. 5th Circuit Judges, 884 F.2d 221 , 222–223 (5th Cir. 1990) (noting the absence of jurisdiction where plaintiff did not comply …
cited Cited "see" Alvin Lee Martin, Cheryl Martin vs USA
11th Cir. · 2011 · signal: see · confidence high
See Burchfield v. United States, 168 F.3d 1252, 1254-55 (11th Cir.1999).
discussed Cited "see" Neuenswander v. United States
D. Vt. · 2006 · signal: see · confidence high
See generally Burchfield v. United States, 168 F.3d 1252, 1256 (“Section 2675(a) does not require an agency to undertake an independent search for injuries or theories of liability that are not closely related to the matters described in the claim.” (Citation omitted)); Vega v. United States, 68 F.Supp.2d 113, 117 (D.P.R.1999) (“[T]he First Circuit has employed a lenient approach ... keeping in mind that the law was not intended to put up a barrier of technicalities ...
discussed Cited "see" Palay v. United States
N.D. Ill. · 2000 · signal: see · confidence high
See Burchfield v. United States, 168 F.3d 1252, 1255 (11th Cir.1999)(“An administrative agency is deemed to be on notice not only of the theories of recovery stated in the claim, but of the theories of recovery that its reasonable investigation of the specific allegations of the claim should reveal”).
cited Cited "see, e.g." George Bello v. United States
11th Cir. · 2018 · signal: see also · confidence low
See also Burchfield v. United States, 168 F.3d 1252 , 1254–55 (11th Cir. 1999).
discussed Cited "see, e.g." Boles v. United States
M.D.N.C. · 2014 · signal: see also · confidence medium
White, 907 F.Supp.2d at 705 (quoting Owen v. United States, 307 F.Supp.2d 661, 667 (E.D.Pa.2004)); see also Drew, 217 F.3d at 203 (“We do not require the claimant to provide the agency with a preview of his or her lawsuit by reciting every possible theory of recovery ... or every factual detail that might be relevant_In short, the amount of information required is minimal.” (quoting Burchfield v. United States, 168 F.3d 1252, 1255 (11th Cir.1999) (internal quotation marks omitted))).
discussed Cited "see, e.g." Rollin Paul Goodman, in His Individual Capacity v. United States
9th Cir. · 2002 · signal: see also · confidence medium
See, e.g., Broudy, 722 F.2d at 568-69 ; see also Burchfield v. United States, 168 F.3d 1252, 1255 (11th Cir.1999) (stating, “[w]e do not require the claimant to provide the agency with a preview of his or her lawsuit by reciting every possible theory of recovery ... or every factual detail that might be relevant”).
Retrieving the full opinion text from the archive…
Boyd BURCHFIELD, Plaintiff-Appellant,
v.
UNITED STATES of America, Department of Veteran Affairs, Defendants-Appellees
98-2024.
Court of Appeals for the Eleventh Circuit.
Mar 2, 1999.
168 F.3d 1252
Harry M. Hobbs, Walter 0. Hobbs, Jr., Tampa, FL, for Plaintiff-Appellant., Charles R. Wilson, U.S. Attorney, Tamra Phipps, Asst. U.S. Attorney, Susan Roark Waldron, Asst. U.S. Attorney, Tampa, FL, for Defendants-Appellees.
Hatchett, Marcus, Kravitch.
Cited by 50 opinions  |  Published
KRAVITCH, Senior Circuit Judge:

A plaintiff who sues under the Federal Tort Claims Act, 28 U.S.C. §§ 2671 et seq. (“FTCA”), must first present his or her claim to the appropriate federal agency. 28 U.S.C. § 2675(a). This case requires us to determine the amount of information that this claim must contain. Appellant Boyd Burch-field (“Burchfield”) sued the United States pursuant to the FTCA, alleging that the negligence of employees of the Department of Veterans Affairs (“VA”) led to his severe osteoporosis. The district court held that it lacked subject matter jurisdiction over the complaint because the claim that Burchfield had presented to the VA did not satisfy 28 U.S.C. § 2675(a). We conclude that Burch-field’s claim contained sufficient information to meet the presentment requirements of section 2675(a), and therefore reverse and remand for further proceedings.

I.

While on active duty with the United States Army in 1968, Burchfield developed a tumor of the pituitary gland. Army doctors operated to remove the tumor, but it reoccurred in 1986 and Burchfield underwent five additional surgeries, the last in 1990. As a result of the surgeries, Burchfield developed panhypopituitarism (non-functioning of the pituitary gland), which caused his body to stop producing cortisone, thyroid hormone, and testosterone. To replace some of these natural hormones his doctors, VA employees, prescribed a corticosteroid, Pred-nisone. As far as the record before us shows, Burchfield’s doctors did not accompany this prescription with a program of dietary supplements to combat osteoporosis, such as Vitamin D, calcium or calcitonin. The doctors also prescribed injectable testosterone, which can help to restore sexual function and prevent osteoporosis. After a short time Burchfield discontinued the testosterone treatments, telling his doctors that he disliked their side effects and that he was not interested in regaining sexual function. It is not clear whether Burchfield’s doctors informed him that injectable testosterone treatments could help prevent osteoporosis.

[*1254] Beginning as early as 1988, Burchfield developed osteoporosis, which had become severe by 1996. As a result, he suffered various injuries, including rib and sternal fractures and collapsed vertebrae, and is at risk of further injury.

Pursuant, to the requirements of 28 U.S.C. § 2675(a), [1] Burchfield filed an administrative claim on Standard Form 95 with the VA on January 17,1996. The claim stated:

Beginning August of 1990 and in subsequent years, physicians employed by the Department of Veterans Affairs prescribed a medication for Mr. Burchfield, predni-sone. Mr. Burchfield’s use of this medicine caused him to develop osteoporosis, resulting in severe and continuing maladies and injuries, including but not limited to the collapse or fracture of several vertebrae and ribs.... These injuries resulted from negligence of the Department’s agents. [2]

The claim listed thirteen doctors who had treated Burchfield. After six months, during which the VA failed to make a final disposition of the claim, Burchfield filed suit in district court. His complaint alleged, inter alia, that osteoporosis was a “known and anticipated effect! ] of corticosteroid therapy” [3] and that his doctors were negligent in failing to initially diagnose osteoporosis, to monitor him for the condition during his treatment, and to administer a bone strengthening regimen. [4] At the bench trial, Burchfield’s medical expert, Dr. Thomas Zizic, stated that prescribing the corticosteroid Prednisone did not in itself deviate from the standard of care. [5] He testified, however, that Burchfield’s doctors deviated from the standard of care by treating him with Pred-nisone without taking certain other steps, such as performing initial baseline tests for osteoporosis and prescribing such supplements as calcium and Vitamin D to counteract the treatment’s effects. [6]

After Dr. Zizic testified, the district court addressed the issue of its jurisdiction under the FTCA. It found that Burchfield’s administrative claim had alleged only that the VA’s doctors were negligent in prescribing Predni-sone, while at trial Burchfield had raised a “significant[ly] different claim! ]” that the VA had “caus[ed] or contributed] to the exacerbation of osteoporosis by failing to diagnose it properly and by failing to treat it properly.” [7] On the basis of this distinction, the district court held that Burchfield had failed to meet the requirements of section 2675(a) by putting the VA on notice of his allegations, and that it therefore lacked subject matter jurisdiction over Burchfield’s claim. The court entered judgment as a matter of law in favor of the United States.

II.

We review a district court’s grant of judgment as a matter of law de novo. Morris v. Crow, 117 F.3d 449, 455 (11th Cir.1997).

A plaintiff bringing a claim against the United States under the FTCA must first present the claim to the appropriate federal agency and wait for the agency to finally deny it. An agency’s failure to dispose of a claim within six months is deemed to be a final denial. See 28 U.S.C. § 2675(a). A district court only has jurisdiction over an FTCA action if the plaintiff has met section[*1255] 2675(a)’s requirements. See Bush v. United States, 703 F.2d 491, 494 (11th Cir.1983).

To satisfy section 2675(a), a claimant must do two things: “(1) give[ ] the [appropriate] agency written notice of his or her claim sufficient to enable the agency to investigate and (2) placet ] a value on his or her claim.” Adams v. United States, 615 F.2d 284, 289 (5th Cir.), decision clarified on denial of reh’g, 622 F.2d 197 (5th Cir.1980). [8] Because Burchfield’s administrative claim placed a dollar value on his alleged damages, [9] the only issue before us is whether his claim gave notice of the allegations he made at trial. We must determine whether the administrative claim’s statement that Burch-field’s “use of [Prednisone]” caused his injuries, along with its list of medical providers, was sufficient to put the VA on notice that Burchfield could allege negligence in matters closely related to the Prednisone prescription, such the doctors’ failure to prescribe supplements to counteract the Prednisone’s effects. We hold that Burchfield’s administrative claim did put the VA on notice of such allegations. The legislative history of section 2675(a) and our own precedents guide our inquiry.

Congress had a dual purpose in enacting section 2675(a): to encourage prompt settlement of claims and to ensure fairness to FTCA litigants. The Senate reported that the law was intended to “pro-vid[e] for more fair and equitable treatment of private individuals and claimants when they deal with the Government or are involved in litigation with their Government.” S.Rep. No. 89-1327, at 2 (1966), reprinted in 1966 U.S.C.C.A.N. 2515, 2515-16 (quoting House report). It further stated that the administrative claim requirement, by giving agencies an opportunity to settle suits before litigation commenced, would “ease court congestion and avoid unnecessary litigation, while making it possible for the Government to expedite the fair settlement of tort claims asserted against the United States.” Id. at 2, reprinted in 1966 U.S.C.C.A.N. at 2516 (quoting House report); see also McNeil v. United States, 508 U.S. 106, 111-12, 113 S.Ct. 1980, 1983, 124 L.Ed.2d 21 (1993) (stating that purpose of section 2675(a) is to give federal agencies “a fair opportunity to investigate and possibly settle ... claim[s]”); Adams, 615 F.2d at 288 (noting legislative history evidencing statute’s purpose). Congress, therefore, enacted section 2675(a) not to place procedural hurdles before potential litigants, but to facilitate early disposition of claims. See, e.g., Lopez v. United States, 758 F.2d 806, 809 (1st Cir.1985) (“[I]ndividuals wishing to sue the government must comply with the details of [section 2675], but ... the law was not intended to put up a barrier of technicalities to defeat their claims.”).

We keep section 2675(a)’s underlying purpose in mind when considering the amount of information it requires from a potential litigant. We have held that a claimant must give an administrative agency only enough information to allow the agency to “begin its own investigation” of the alleged events and explore the possibility of settlement. Adams, 615 F.2d at 292. We do not require the claimant to provide the agency with a preview of his or her lawsuit by reciting every possible theory of recovery, see Brown v. United States, 838 F.2d 1157, 1160-61 (11th Cir.1988), or every factual detail that might be relevant, see Adams, 615 F.2d at 291-92. In short, the amount of information required is “minimal.” Id. at 289.

An administrative agency is deemed to be on notice not only of the theories of recovery stated in the claim, but of the theories of recovery that its reasonable investigation of the specific allegations of the claim should reveal. In Rise v. United States, 630 F.2d 1068 (5th Cir.1980), the plaintiff presented an administrative claim that Army physicians failed to diagnose and treat his wife’s aneurysm. After bringing suit on that assertion, he amended his complaint to allege[*1256] that the Army also was negligent in referring his wife to a civilian hospital and failing to supervise her treatment there. We stated that “if the Government’s investigation of Rise’s claim should have revealed theories of liability other than those specifically enumerated therein, those theories can properly be considered part of the claim.” Id. at 1071.

The district court in this case noted Rise’s holding that an administrative claim does not need specifically to enumerate all possible theories of liability. It nonetheless found that Burchfield’s claim could not give notice of the issues raised in his lawsuit; this was not because Burchfield had failed to lay out all of his legal theories, but because he had not drawn the VA’s attention to certain facts, such as his doctors’ failure to diagnose osteoporosis, perform initial tests, and prescribe Vitamin D or calcium. [10] We conclude that the court interpreted Rise too narrowly. An administrative claim can put an agency on notice of theories of liability not spelled out therein. All that is required is that the theory put forward in the complaint filed in the district court be based on the facts that are stated in the administrative claim.

In this case, it is hard to imagine what facts Burchfield could have included in his administrative claim that would have allowed the VA to conduct a more thorough investigation of the claim. The claim stated all the essential aspects of Burchfield’s case — the time period, the fact that his doctors had prescribed Prednisone, the causal link between his use of the Prednisone and his osteoporosis, and the assertion that the VA’s agents were negligent — although it did not contain every factual detail that he later introduced at trial. These other details, such as his doctors’ failure to prescribe dietary supplements and to monitor his condition, were so closely related to the essential material contained in the claim that they would have come to light during the VA’s reasonable investigation of the claim. An agency cannot use an overly technical reading of the language of a claim as a reason to turn a blind eye to facts that become obvious when it investigates the alleged events.

In Rise, we held that because the plaintiffs administrative claim mentioned a patient’s transfer to a civilian hospital, “the Army’s investigation of the death should have produced ... evidence that [the civilian hospital’s] facilities may have been inadequate ... and, consequently, that referring Mrs. Rise there might have been negligence.” Rise, 630 F.2d at 1071. The Second Circuit similarly has held that an administrative claim can put an agency on notice of facts it should discover during its investigation of the claim. In Johnson by Johnson v. United States, 788 F.2d 845, 848-49 (2d Cir.1986), it found that an administrative claim, which alleged that a government employee had attacked a minor but did not mention facts suggesting that anyone other than the employee was at fault, gave the government sufficient notice of the plaintiffs negligent supervision claim. “Although the claim supplied no facts evidencing negligent supervision and did not allege all the factual elements of such a theory of liability, a reasonably thorough investigation of the incident should have uncovered any pertinent information in the government’s possession relating to the agency’s knowledge, or lack of knowledge, of any prior sexual misconduct by its employee_” Id. at 849 (citing Rise).

Our holding does not mean that agency investigations must go beyond the scope of the matters alleged in administrative claims. Section 2675(a) does not require an agency to undertake an independent search for injuries or theories of liability that are not closely related to the matters described in the claim. See Orlando Helicopter Airways v. United States, 75 F.3d 622, 626 (11th Cir.1996) (holding that contract readjustment claim alleging misconduct by a whistleblower did not give notice of allegations of misconduct by government officials); Bush, 703 F.2d at 495 (holding that administrative claim alleging medical malpractice that contained no challenge to consent form or disclosure of risks did not give notice of claim based on lack of the patient’s informed consent); see also Deloria v. Veterans Admin., 927 F.2d 1009, 1012 (7th Cir.1991)[*1257] (holding that investigation of charge that officials altered medical records would not give notice of malpractice charges that involved “wholly distinct incidents”). Nor does our interpretation of the statute mean that an agency will be on notice of all the facts contained in voluminous records presented by a claimant, if the claimant has not pointed to specific sources of injury. See Bembenista v. United States, 866 F.2d 493, 498-99 (D.C.Cir.1989) (holding that plaintiff did not satisfy notice requirement when the few facts at issue were buried in “more than 400 pages of medical records, transcripts, and Army documents”); Deloria, 927 F.2d at 1012 (citing Bembenista). Finally, a claim may be so vague or lacking in detail that the agency cannot be expected to initiate any investigation at all. See Tidd v. United States, 786 F.2d 1565, 1568 (11th Cir.1986) (“For an agency to be able to initiate an investigation into a tort claim ... it must be apprised of the location and approximate date of the incident.”); see also Romulus v. United States, 160 F.3d 131, 132 (2d Cir.1998) (“A claimant must provide more than eonclusory statements which afford the agency involved no reasonable opportunity to investigate.”).

Here, Burchfield’s administrative claim stated that his doctors prescribed Prednisone and that his “use of’ the Prednisone caused osteoporosis. It gave the VA sufficient information, including the dates of his treatment and the names of his doctors, to allow the VA to refer to the medical records in its possession to investigate Burchfield’s use of the medication and the surrounding circumstances. Burchfield presented evidence, in the form of Dr. Zizic’s testimony, that a doctor who prescribed Prednisone to a patient in Burchfield’s condition had a duty to monitor, and take steps to prevent, the medication’s side effects. A person with reasonable expertise in medicine, investigating Burchfield’s claim that his use of Prednisone caused osteoporosis, would therefore have asked whether the doctors who prescribed the Prednisone also undertook the closhly related tasks of prescribing appropriate accompanying medication, such as calcium and Vitamin D, and monitoring the drug’s effects, and would have discovered that they did not. Thus, Burchfield’s administrative claim satisfied the requirements of section 2675(a) by giving the VA notice of the claims that he raised at trial, and the district court erred in finding that it lacked subject matter jurisdiction.

III.

Accordingly, we REVERSE the decision of the district court and REMAND the case for further proceedings in accordance with this opinion.

1

. Section 2675(a) states, in relevant part:

An action shall not be instituted upon a claim against the United States for money damages ... unless the claimant shall have first presented the claim to the appropriate Federal agency and his claim shall have been finally denied by the agency in writing.... The failure of an agency to make final disposition of a claim within six months after it is filed shall, at the option of the claimant any time thereafter, be deemed a final denial of the claim for purposes of this section.
2

. Rl-37 at 5. Burchfield also claimed that the VA employees' negligence caused "a vascular right hip necrosis, and the replacement of his right hip with a prosthetic,” id., but he did not pursue this claim at trial.

3

. Compl., Rl-1 at 3, ¶ 9(c).

4

. Id. at 2-3, ¶¶ 8-9.

5

. Trial Tr., R2-43 at 99.

6

. Id. at 52-60, 99.

7

. Id. at 146.

8

. Decisions by the former Fifth Circuit issued before October 1, 1981 are binding precedent in the Eleventh Circuit. See Bonner v. City of Prichard, 661 F.2d 1206, 1207 (11th Cir.1981) (en banc).

9

. See Rl-37 at 2, 3.

10

. Trial Tr., R2-43 at 140-46.