CHENOWETH v. United States
1:15-cv-00029
Fed. Cl.Jan 27, 2015Background
- Pro se plaintiff Michael Chenoweth sued the United States in the U.S. Court of Federal Claims seeking over $500,000,000 and other relief, alleging crimes and torts by "Maui Chemical."
- Chenoweth previously sued his former employer, Maui Chemical & Paper Products, Inc., in the U.S. District Court for the District of Hawai'i (2007); summary judgment for the employer was affirmed by the Ninth Circuit.
- Chenoweth contends the United States is "fully responsible" for Maui Chemical's acts because federal courts dismissed his suit against Maui Chemical.
- The Court of Federal Claims must dismiss actions when it lacks subject-matter jurisdiction and reads pro se pleadings liberally but still requires jurisdictional sufficiency.
- The court found it lacks jurisdiction to (a) review decisions of other federal courts or their employees, and (b) hear standalone civil-rights claims against the United States in this forum.
- Conclusion: Complaint dismissed for lack of subject-matter jurisdiction; clerk directed to enter judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Court of Federal Claims has subject-matter jurisdiction over Chenoweth's suit | Chenoweth: the United States is liable for Maui Chemical's conduct because federal courts dismissed his case | United States: the court lacks jurisdiction to hear claims against parties other than the U.S. and to review other courts' decisions | Dismissed for lack of subject-matter jurisdiction |
| Whether the court may review or redress actions/decisions of district courts or their clerks | Chenoweth: dismissal by federal courts makes the U.S. responsible | U.S.: CFClaims cannot review or overturn district court decisions | Court: it has no jurisdiction to review district court decisions |
| Whether civil-rights claims against the United States lie in Court of Federal Claims | Chenoweth: asserts civil-rights violations by the U.S. | U.S.: CFClaims does not have jurisdiction over such civil-rights claims here | Court: civil-rights claims are not within this court's jurisdiction |
| Whether pro se status relaxes jurisdictional requirements | Chenoweth: pro se pleading should be construed liberally | U.S.: pro se status does not relieve jurisdictional limits | Court: granted liberal construction but still required jurisdiction; dismissal upheld |
Key Cases Cited
- Arbaugh v. Y & H Corp., 546 U.S. 500 (subject-matter jurisdiction cannot be forfeited or waived)
- Haines v. Kerner, 404 U.S. 519 (pro se pleadings receive liberal construction)
- United States v. Sherwood, 312 U.S. 584 (Court of Federal Claims jurisdiction limited to money judgments against the United States)
- Brown v. United States, 105 F.3d 621 (Fed. Cir.) (confirming jurisdictional limits of the Court of Federal Claims)
- LeBlanc v. United States, 50 F.3d 1025 (Fed. Cir.) (Court of Federal Claims lacks jurisdiction over certain civil-rights claims)
- Joshua v. United States, 17 F.3d 378 (Fed. Cir.) (CFClaims cannot review district court or clerk actions)
- Cotton v. United States, 535 U.S. 625 (jurisdictional issues are fundamental to a court's power to hear a case)
- Moore v. Public Defender's Office, 76 Fed. Cl. 617 (Court of Federal Claims discussion of its jurisdictional boundaries)