Gonzalez v. United States, 16-1207

Background

Pro se plaintiff David Gonzalez, a federal inmate serving life sentences from multiple district-court convictions, filed a complaint in the Court of Federal Claims seeking release and millions in damages.
Gonzalez alleged multiple constitutional violations (Fourth, Fifth, Sixth, Eighth, Ninth, Tenth, Thirteenth Amendments) and sought reversal of his criminal convictions and money damages for alleged malicious prosecution and unlawful incarceration.
The complaint named the Department of Justice and DOJ personnel as defendants and sought relief directed at those individuals and the prior district-court judgments.
The Court of Federal Claims reviewed jurisdiction sua sponte under RCFC 12(h)(3) and the Tucker Act, which provides this court jurisdiction only over claims against the United States that are "money-mandating."
The court found Gonzalez’s claims either directed at individual federal officials (not the United States), seeking review/reversal of other courts’ criminal judgments, or asserting constitutional provisions that are not money-mandating, and thus outside the court’s jurisdiction.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Court of Federal Claims has jurisdiction over claims seeking money for constitutional violations	Gonzalez contended his incarceration and alleged deprivation of liberty constituted a taking/constitutional violations entitling him to money damages	The government argued the Tucker Act limits this court to money-mandating rights against the United States; many constitutional claims do not mandate money relief	Court held it lacked jurisdiction because the asserted constitutional provisions are not money-mandating and thus do not create Tucker Act jurisdiction
Whether claims against DOJ personnel can be heard in this court	Gonzalez sued DOJ and its personnel for damages related to his prosecution and incarceration	The government argued suits against individual federal officials are beyond the Court of Federal Claims’ jurisdiction (which is against the United States)	Court held claims against individual federal officers are outside its jurisdiction and must be ignored
Whether the court can grant relief that would reverse prior district-court criminal convictions	Gonzalez requested reversal of his convictions and release from custody	The government argued the Court of Federal Claims lacks authority to review or modify other courts’ criminal judgments	Court held it cannot review or overturn decisions of other federal courts and cannot grant relief from convictions
Whether transfer to another federal court under 28 U.S.C. § 1631 is appropriate	Gonzalez implicitly sought a forum where his claims could be considered on the merits	The government urged dismissal for lack of jurisdiction; transfer should be considered only if claims are nonfrivolous and transfer would serve justice	Court exercised discretion and declined transfer, finding no nonfrivolous claim that merits transfer; dismissed for lack of jurisdiction

Key Cases Cited

Folden v. United States, 379 F.3d 1344 (Fed. Cir.) (subject-matter jurisdiction may be raised sua sponte and is decided on the face of the pleadings)
Metabolite Labs., Inc. v. Lab. Corp. of Am. Holdings, 370 F.3d 1354 (Fed. Cir.) (court must address jurisdiction sua sponte)
Haines v. Kerner, 404 U.S. 519 (U.S.) (pro se pleadings held to less stringent standards)
Brown v. United States, 105 F.3d 621 (Fed. Cir.) (Court of Federal Claims has jurisdiction over suits against the United States, not individual federal officials)
United States v. Navajo Nation, 556 U.S. 287 (U.S.) (substantive law must be fairly interpreted as mandating compensation by the federal government to confer Tucker Act jurisdiction)
Testan v. United States, 424 U.S. 392 (U.S.) (Tucker Act requires a separate money-mandating source of substantive law)
Joshua v. United States, 17 F.3d 378 (Fed. Cir.) (Court of Federal Claims lacks jurisdiction to review decisions of other courts)
United States v. Sherwood, 312 U.S. 584 (U.S.) (relief sought against parties other than the United States must be ignored by the Court of Federal Claims)