Gravatt v. United States
100 Fed. Cl. 279
Fed. Cl.2011Background
- Gravatt, a federal prisoner proceeding pro se, sues the United States claiming the U.S. holds funds in a trust account for him and must remit them.
- He attached numerous documents (UCC statements, tax forms, correspondence with federal courts, notarized letters/affidavits, birth certificate) to support his claims.
- Court grants summary adjudication, dismissing the complaint for lack of jurisdiction and deeming it frivolous.
- Plaintiff espouses sovereign citizen beliefs, asserting he is not a U.S. citizen and that birth certificates/SSNs create government contracts.
- The factual allegations track a sovereign-citizen scheme involving a fictitious trust funded by the government and “redemption” of funds, coupled with prior filings in other courts.
- Plaintiff’sComplaint was filed in September 2011; prior related filings concerned tax refunds and claims against the government.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether jurisdiction exists under the Tucker Act | Gravatt asserts express/implied contracts with the United States. | The alleged contracts are frivolous; no money-mandating basis exists. | Lacks jurisdiction; claims are frivolous. |
| Express contract claim based on birth certificate/SSN | Birth certificate/SSN constitute express contracts with the U.S. | Birth certificates/SSNs are not contracts; no contract exists. | Dismissed for lack of jurisdiction. |
| Implied-in-fact/implied-in-law contract claims | There is an implied contract with the United States. | No valid implied-in-fact contract proven; implied-in-law contracts dismissed. | Dismissed for lack of jurisdiction. |
| Whether § 2042 is money-mandating and supports jurisdiction | § 2042 provides a money-mandating basis for relief. | § 2042 governs funds deposited with a court, not government obligations to pay damages. | Not money-mandating; dismissed. |
| Whether §§ 1321/1322 provide jurisdiction | These provisions create a trust-based entitlement to funds. | No credible trust funds exist; claims are frivolous. | Dismissed for lack of jurisdiction. |
| Equitable relief in absence of money judgment | Seeks declaratory/injunctive relief alongside damages. | Equitable relief requires a money judgment. | Dismissed for lack of jurisdiction. |
Key Cases Cited
- United States v. Sherwood, 312 U.S. 584 (1941) (sovereign immunity waiver must be unequivocally expressed)
- Ex parte McCardle, 74 U.S. (7 Wall.) 506 (1868) (threshold jurisdiction question; dismissal if no jurisdiction)
- United States v. Testan, 424 U.S. 392 (1976) (money damages require a money-mandating source)
- Loveladies Harbor, Inc. v. United States, 27 F.3d 1545 (Fed. Cir. 1994) (en banc; money-mandating sources must exist for Tucker Act claims)
- Hanlin v. United States, 214 F.3d 1319 (Fed.Cir.2000) (non-frivolous implied-in-fact contract pleading required)
- City of El Centro v. United States, 922 F.2d 816 (Fed.Cir.1990) (elements of implied-in-fact contract)
- Jan’s Helicopter Serv., Inc. v. FAA, 525 F.3d 1299 (Fed.Cir.2008) (nonfrivolous assertion required for jurisdiction under money-mandating sources)
- Bryant v. Wash. Mut. Bank, 524 F. Supp. 2d 753 (W.D. Va. 2007) (sovereign-citizen schemes lack legal basis; dismissal for lack of jurisdiction)
- Reynolds v. Army & Air Force Exch. Serv., 846 F.2d 746 (Fed.Cir.1988) (pro se pleadings held to less stringent standards but must show jurisdictional basis)
- Migra v. Warren City Sch. Dist. Bd. of Educ., 465 U.S. 75 (1984) (collateral estoppel considerations in filings)
- Stee l Co. v. Citizens for a Better Env’t, 523 U.S. 83 (1998) (jurisdiction and merits framework regarding abstention and threshold questions)