Allen v. United States
546 F. App'x 949
Fed. Cir.2013Background
- Allen previously sued healthcare providers in the Middle District of Alabama; that district court dismissed his complaint for failure to state a claim and Allen did not appeal.
- Allen then filed in the U.S. Court of Federal Claims seeking $800,000,000 from the United States, alleging improper actions by district court officials (judges, magistrate judge, clerk) arising from the prior dismissal.
- He claimed violations of the Fourth, Fifth, and Fourteenth Amendments, the Americans with Disabilities Act (ADA), the Alternative Dispute Resolution Act (ADR Act), and various district-court rules, and argued those provisions supported Tucker Act jurisdiction for monetary relief.
- The Claims Court held it lacked Tucker Act jurisdiction because none of the asserted constitutional provisions, the ADA, the ADR Act, or the cited court rules is a money-mandating source that would compel payment by the United States.
- The Claims Court denied Allen’s motion to transfer the case back to district court, reasoning transfer would not be in the interest of justice given the low likelihood of success and no evident statute-of-limitations problem.
- Allen appealed; the Federal Circuit reviewed jurisdiction de novo and the transfer denial for abuse of discretion and affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Claims Court has Tucker Act jurisdiction over Allen’s monetary claims | Allen: Constitutional provisions, ADA, ADR Act, and court-rule violations support money-mandating claims against the U.S. | Gov’t: None of those sources are money-mandating; Claims Court lacks Tucker Act jurisdiction | No Tucker Act jurisdiction; dismissal affirmed |
| Whether the Fourth, Fifth, and Fourteenth Amendments mandate money damages from the U.S. | Allen: Constitutional violations entitle him to monetary relief in Claims Court | Gov’t: These constitutional provisions do not constitute money-mandating law for Tucker Act purposes | Court: Constitutional provisions cited are not money-mandating; jurisdiction lacking |
| Whether ADA or ADR Act create money-mandating obligations to support Claims Court jurisdiction | Allen: ADA and ADR Act violations support monetary claims | Gov’t: ADA and ADR Act are not read to mandate payment by the federal government | Court: ADA and ADR Act are not money-mandating; no jurisdiction |
| Whether the Claims Court abused its discretion in denying transfer to district court | Allen: Transfer would be in the interest of justice | Gov’t: Transfer not warranted; case likely futile and no clear statute-of-limitations barrier to filing anew in district court | Court: Denial of transfer was within discretion; affirmed |
Key Cases Cited
- United States v. Navajo Nation, 556 U.S. 287 (2009) (Tucker Act requires money-mandating source to establish Claims Court jurisdiction)
- Brown v. United States, 105 F.3d 621 (Fed. Cir. 1997) (Fourth Amendment claims fall outside Tucker Act jurisdiction)
- Carruth v. United States, 627 F.2d 1068 (Ct. Cl. 1980) (Fifth Amendment due process/equal protection not money-mandating)
- LeBlanc v. United States, 50 F.3d 1025 (Fed. Cir. 1995) (Fourteenth Amendment claims do not mandate payment by government)
- Western Co. v. United States, 323 F.3d 1024 (Fed. Cir. 2003) (jurisdiction questions in Claims Court reviewed de novo)
- Zoltek Corp. v. United States, 672 F.3d 1309 (Fed. Cir. 2012) (transfer-denial legal issues reviewed de novo; abuse of discretion standard for transfer)
- Searles v. United States, 88 Fed. Cl. 801 (2009) (Claims Court lacks jurisdiction over ADA-based claims)