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Grant v. United States
129 Fed. Cl. 790
| Fed. Cl. | 2017
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Background

  • 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)
Read the full case

Case Details

Case Name: Grant v. United States
Court Name: United States Court of Federal Claims
Date Published: Jan 17, 2017
Citation: 129 Fed. Cl. 790
Docket Number: 16-1621C
Court Abbreviation: Fed. Cl.