Croteau v. United States
17-173
| Fed. Cl. | Sep 22, 2017Background
- Plaintiff Ronald Francis Croteau, a federal prisoner convicted of tax-related crimes, sued the United States seeking $120,315,000 for alleged constitutional violations and torts by unnamed IRS agents.
- Complaint (pro se) alleged violations of the First, Fourth, Fifth, Sixth, Seventh, Tenth, and Thirteenth Amendments, various torts (fraud, malpractice), and sought unspecified equitable relief including a declaration he is not a U.S. citizen.
- The government moved to dismiss under RCFC 12(b)(1) for lack of subject-matter jurisdiction, arguing no money‑mandating source and that torts and collateral attacks on criminal proceedings are outside this court’s jurisdiction.
- Plaintiff filed multiple pro se responses, motions for default judgment, and a request for oral argument; the court denied default judgment and oral argument and treated filings liberally.
- The Court considered the Tucker Act’s requirement that a constitutional or statutory source be money‑mandating and evaluated whether any pleaded claim fell within the Court of Federal Claims’ limited jurisdiction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether constitutional claims provide Tucker Act jurisdiction (money‑mandating) | Croteau contends constitutional violations entitle him to money damages | Government: cited amendments are not money‑mandating and thus do not invoke Tucker Act jurisdiction | Court: Dismissed—constitutional provisions cited are not money‑mandating; no jurisdiction |
| Whether tort claims (fraud, malpractice) are within court's jurisdiction | Croteau alleged fraud and malpractice against IRS agents | Government: Tucker Act excludes claims sounding in tort | Court: Dismissed—fraud and malpractice sound in tort and are outside jurisdiction |
| Whether this court can review or relitigate district court criminal proceedings | Croteau sought relief tied to his criminal prosecution and decisions of the Middle District of Florida | Government: this court is not an appellate tribunal for other federal courts | Court: Dismissed—no jurisdiction to review district court decisions |
| Whether equitable relief (declaratory relief re: citizenship) is available absent valid money claim | Croteau requested equitable/declaratory relief, including a claim he is not a U.S. citizen | Government: equitable relief is not available here without a collateral monetary claim | Court: Dismissed—court cannot grant non‑collateral equitable relief without a valid money claim |
Key Cases Cited
- Folden v. United States, 379 F.3d 1344 (Fed. Cir.) (subject‑matter jurisdiction may be raised at any time and pleadings are taken as true for jurisdictional analysis)
- Smith v. United States, 709 F.3d 1114 (Fed. Cir.) (Due Process Clause is not money‑mandating for Tucker Act jurisdiction)
- United States v. Connolly, 716 F.2d 882 (Fed. Cir.) (First Amendment not money‑mandating)
- Joshua v. United States, 17 F.3d 378 (Fed. Cir.) (Court of Federal Claims lacks jurisdiction to review district court decisions)
- Sellich v. United States, 222 Ct. Cl. 679 (fraud claims sound in tort and fall outside Tucker Act jurisdiction)
- City of El Centro v. United States, 922 F.2d 816 (Fed. Cir.) (limitations on treating non‑government instruments as contracts with the United States)
- Nat'l Air Traffic Controllers Ass'n v. United States, 160 F.3d 714 (Fed. Cir.) (equitable relief before the Court of Federal Claims must be collateral to a valid money claim)