Grant v. United States
129 Fed. Cl. 790
| Fed. Cl. | 2017Background
- Plaintiff William Lee Grant, II, a pro se litigant, filed a complaint and an application to proceed in forma pauperis (IFP) in the Court of Federal Claims.
- Grant's complaint raised various criminal and constitutional accusations against public figures (e.g., DOJ program, state officials, Hillary Clinton, Cheney, Rumsfeld) and sought judicial action (including DNA testing and trials).
- The Court reviewed jurisdictional prerequisites: the Court of Federal Claims may award money judgments only when grounded in a contract, money‑mandating statute, or the Takings Clause. Grant did not allege a money‑mandating source.
- The Court noted Grant’s extensive litigation history presenting similar claims in federal courts, which had been dismissed as frivolous and for failure to state a claim; an appeal to the Seventh Circuit was pending.
- Under 28 U.S.C. § 1915(e)(2)(B) the Court must dismiss frivolous IFP complaints; the Court also may deny IFP status where the plaintiff’s filings are vexatious and duplicative.
- The Court denied Grant’s IFP application and dismissed the complaint as frivolous and for lack of subject‑matter jurisdiction; judgment entered for the United States.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Court has jurisdiction to hear Grant’s claims against government actors | Grant sought relief including investigations, trials, DNA testing and constitutional redress for alleged government misconduct | United States argued claims are not grounded in a contract, money‑mandating statute, or Takings Clause and thus outside Court of Federal Claims jurisdiction | Dismissed for lack of subject‑matter jurisdiction; Court requires a money‑mandating source for relief |
| Whether the complaint is frivolous under 28 U.S.C. § 1915(e)(2)(B) | Grant advanced sensational and varied allegations against public figures that he presented as cognizable claims | United States argued claims are fantastic, repetitive, and lack an arguable basis in law or fact | Complaint dismissed as frivolous; allegations characterized as fantastic/delusional |
| Whether to grant in forma pauperis status | Grant requested waiver of filing fees due to indigence | United States opposed, citing Grant’s history of vexatious and duplicative lawsuits | IFP denied based on plaintiff’s history of frivolous litigation and abuse of judicial process |
| Whether further proceedings or evidentiary hearing were warranted | Grant’s filings sought substantive fact‑finding and relief | United States asserted no basis for further proceedings given lack of jurisdiction and frivolous nature | No further proceedings; dismissal affirmed without evidentiary hearing |
Key Cases Cited
- Neitzke v. Williams, 490 U.S. 319 (defining frivolous suits and explaining claims lacking arguable legal or factual basis)
- United States v. Testan, 424 U.S. 392 (holding Court of Federal Claims jurisdiction requires a money‑mandating substantive source)
- United States v. Navajo Nation, 556 U.S. 287 (explaining when a statute can be fairly interpreted as mandating compensation)
- Taylor v. United States, [citation="568 F. App'x 890"] (affirming dismissal of fantastical and frivolous claims under § 1915)
- Folden v. United States, 379 F.3d 1344 (subject‑matter jurisdiction may be raised sua sponte)
- Todd v. United States, 386 F.3d 1091 (plaintiff must identify substantive right to money damages apart from Tucker Act)
- Fiebelkorn v. United States, 77 Fed. Cl. 59 (standard for inability to pay under § 1915)
- Hayes v. United States, 71 Fed. Cl. 366 (applicability of § 1915 to non‑prisoner plaintiffs in Court of Federal Claims)
- Hebert v. United States, 114 Fed. Cl. 590 (failure to meet jurisdictional requirements cannot be excused for pro se plaintiffs)
