Braun v. United States Post Office, Civil Action No. 2016-2079

Background

Plaintiff David S. Braun (pro se) filed suit under the Privacy Act alleging USPS allowed fictitious names/entries to be associated with his address in a national database, causing various harms (surveillance, employment and benefits problems, medical record errors, etc.).
Braun also submitted FTCA claims (Standard Form 95) to the Social Security Administration seeking compensation for delayed Social Security benefits and moved for mandamus relief to compel OMB to process those claims.
Defendants: USPS filed a partial motion to dismiss all claims except Privacy Act claims; OMB moved to dismiss for lack of jurisdiction and failure to state a claim. Braun separately moved for the court to correct the name on one of his P.O. boxes.
The complaint included numerous exhibits and a broad array of allegations, many not clearly tied to a legal theory; Braun sought large monetary relief and various corrective actions.
The Court dismissed Braun’s mandamus/FTCA request for lack of jurisdiction (Social Security Act §405(h) bars such claims), dismissed OMB from the case for failure to state a claim, granted USPS’s motion insofar as only Braun’s Privacy Act claims could proceed, and denied Braun’s motion for corrective action regarding the P.O. box.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court can compel OMB to process FTCA claims for Social Security benefits (mandamus)	Braun asked the court to direct OMB to process his Standard Form 95 claims for delayed Social Security benefits	OMB: jurisdiction barred by the Social Security Act; mandamus improper	Denied — court lacks jurisdiction; §405(h) precludes FTCA relief for Social Security benefit disputes
Whether sovereign immunity bars Braun’s claims against agencies	Braun asserted Privacy Act and other harms against USPS/OMB	Defendants asserted sovereign immunity shields most claims except where Congress waived immunity (e.g., Privacy Act)	Privacy Act waives immunity for certain claims, so Privacy Act claims against USPS may proceed; other tort/FTCA/postal-negligence claims barred
Whether Braun stated a plausible claim against OMB	Braun alleged speculative involvement of OMB in a purported ‘‘settlement agreement’’/database entry affecting his litigation	OMB: complaint contains no factual allegations tying OMB to wrongdoing; fails plausibility standard	Dismissed under Rule 12(b)(6) — no plausible factual allegations against OMB
Scope of claims against USPS and relief for P.O. box name change	Braun sought broad relief against USPS for many alleged harms and requested court assistance to change a P.O. box registration	USPS: only Braun’s Privacy Act requests are cognizable; other allegations are implausible or barred; P.O. box name change is not a proper preliminary-injunction request	Court dismissed non-Privacy Act claims against USPS; Privacy Act requests may proceed. Motion to correct P.O. box denied (no preliminary-injunction showing; administrative remedy available)

Key Cases Cited

Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375 (court of limited jurisdiction principle)
Lujan v. Defenders of Wildlife, 504 U.S. 555 (plaintiff bears burden to establish jurisdiction)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (pleading must be plausible)
Ashcroft v. Iqbal, 556 U.S. 662 (plausibility standard for pleadings)
FDIC v. Meyer, 510 U.S. 471 (sovereign immunity and waiver principles)
Lane v. Pena, 518 U.S. 187 (waiver of sovereign immunity strictly construed)
Dolan v. U.S. Postal Serv., 546 U.S. 481 (Postal Service immunity for delayed/lost mail-related injuries)
FAA v. Cooper, 566 U.S. 284 (Privacy Act authorizes damages against the government)
Weinberger v. Salfi, 422 U.S. 749 (Social Security Act limits judicial review/claims for benefits)
Winter v. Nat. Res. Def. Council, Inc., 555 U.S. 7 (preliminary injunction standards)