At a hearing Friday in federal court in Alexandria, a judge dismissed the lawsuit filed by 19-year-old Gulet Mohamed.
The judge said an amended suit is needed so he can decide if he has jurisdiction.
Mohamed, a U.S. citizen born in Somalia, traveled in 2009 and 2010 to Yemen, Somalia and eventually Kuwait. There he says he was arrested, questioned by FBI agents and beaten by Kuwaiti interrogators.
His efforts to return home were delayed by his apparent placement on the no-fly list.
Mohamed was eventually allowed to fly home, and the government says the case is moot.