Central Pines Land Co. v. United States
697 F.3d 1360
| Fed. Cir. | 2012Background
- Central Pines appeals a Claims Court dismissal for lack of jurisdiction under 28 U.S.C. § 1500 due to a pending district court action.
- Plaintiffs challenged ownership of mineral rights in Vernon Parish, Louisiana, asserting government moratoria and post-1992 leases as taking or title questions.
- District court resolved Group A and Group B issues against Central Pines and left Group C as the only viable claim, with the Fifth Circuit affirming and certiorari denied.
- In parallel, Central Pines filed a Claims Court action in 1998 alleging a takings claim, initially seeking relief consistent with the district court action.
- A stay was in place until 2002; after lifting, the Claims Court allowed amendments in 2003, maintaining similar factual bases to the district court complaint.
- The Claims Court later dismissed Group A and B claims and limited Group C to post-1992 action, then, after trial, awarded temporary compensation for protective leases issued after 1997.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether § 1500 bars the Claims Court action | Central Pines contends the two actions rely on different time periods and thus are not the same claim. | The government contends the Complaints share substantially identical operative facts, triggering § 1500. | Yes; § 1500 bars the Claims Court action. |
| Whether a supplemental complaint cures § 1500 deficiency | Supplemental amendment in 2003 purportedly created jurisdiction. | Supplemental complaint cannot cure the jurisdictional defect once filed during a co-pending district action. | No; supplemental complaint cannot cure the § 1500 bar. |
| What governs the time-of-filing jurisdiction in § 1500 | State of facts at filing should be considered, not later developments. | Jurisdiction is determined by the facts at filing, and pending district court action controls. | Jurisdiction attaches at filing and cannot be revived by later developments. |
| Are the two complaints for the same claim based on substantially overlapping operative facts | Complaints address different time periods and remedies. | They describe nearly identical three mineral servitudes, land histories, and government conduct. | Yes; substantial overlap implicates § 1500. |
Key Cases Cited
- Keene Corp. v. United States, 508 U.S. 200 (U.S. 1993) (time-of-filing jurisdictional bar under § 1500)
- UNR Indus., Inc. v. United States, 962 F.2d 1013 (Fed. Cir. 1992) (en banc; confirms time-of-filing rule for § 1500)
- Tohono O’Odham Nation v. United States, 131 S. Ct. 1723 (S. Ct. 2011) (two suits had substantial overlap of operative facts)
- Trusted Integration, Inc. v. United States, 659 F.3d 1159 (Fed. Cir. 2011) (affirms that § 1500 bars jurisdiction where co-pending action exists)
- Grupo Dataflux v. Atlas Global Group, 541 U.S. 567 (U.S. 2004) (state of filing determines jurisdictional outcome)