Griffen v. United States
21-1836
| Fed. Cl. | Oct 1, 2021Background
- Pro se plaintiff Howard A. Griffen II sued in the U.S. Court of Federal Claims seeking monetary damages for alleged workplace racial discrimination, sexual harassment, and retaliation under Title VII against his former private‑company employer.
- Complaints allege Griffen informed management and was terminated in retaliation; he seeks lost wages, emotional distress damages, and court fees.
- The Court reviewed jurisdiction sua sponte and noted pro se pleadings receive a less stringent reading but must still satisfy jurisdictional requirements.
- The Court explained the Tucker Act limits the Court of Federal Claims to claims against the United States and excludes ordinary torts and Title VII claims against private parties.
- Because Griffen sued a private employer and not the United States, the Court concluded it lacked subject‑matter jurisdiction and dismissed the complaint without prejudice under RCFC 12(h)(3).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Court of Federal Claims has jurisdiction over Title VII claims against a private employer | Griffen alleges Title VII violations by his former private employer and seeks damages | The United States and the Court note the CFC’s jurisdiction is limited to claims against the U.S.; Title VII claims against private parties are outside CFC jurisdiction | Court dismissed for lack of subject‑matter jurisdiction; CFC cannot hear Title VII claims against private employers |
| Effect of pro se status on jurisdictional requirements | Griffen, pro se, argues for liberal construction of his pleadings | Court acknowledges pro se leniency but maintains jurisdictional prerequisites still apply | Court applied relaxed pleading standard but held jurisdictional defect required dismissal |
Key Cases Cited
- Arctic Corner, Inc. v. United States, 845 F.2d 999 (Fed. Cir. 1988) (a court may and should raise jurisdictional doubts sua sponte)
- Folden v. United States, 379 F.3d 1344 (Fed. Cir. 2004) (subject‑matter jurisdiction may be challenged at any time, including sua sponte)
- United States v. Sherwood, 312 U.S. 584 (U.S. 1941) (if relief is sought against others than the United States, the suit must be dismissed)
- Taylor v. United States, [citation="310 F. App'x 390"] (Fed. Cir. 2009) (CFC lacks jurisdiction over Title VII discrimination claims)
- St. Bernard Parish Gov’t v. United States, 916 F.3d 987 (Fed. Cir. 2019) (when a court determines it lacks subject‑matter jurisdiction, it must dismiss the action)