Griffin v. United States
2010 U.S. Claims LEXIS 906
Fed. Cl.2010Background
- Pro se Griffin filed a complaint on behalf of the United States naming State and local Florida entities and officials as defendants.
- Griffin claimed False Claims Act theories and alleged lack of valid oaths of office by state/county personnel.
- Plaintiff sought declarations that certain Florida statutes remained mandatory and sought reimbursement of funds.
- The court dismissed for lack of subject-matter jurisdiction under RCFC 12(h)(3) because the United States was not sued.
- Even if claims were against the United States, the court lacked jurisdiction due to no money-mandating right and because CFA claims aren’t within the Court of Federal Claims.
- The court also found transferring the case inappropriate in light of a prior, similar Florida case and the lack of merit.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Subject-matter jurisdiction over claims against states/localities | Griffin asserts claims on behalf of the United States against Florida entities | Court lacks jurisdiction over state/local entities and officials | Dismissed for lack of jurisdiction |
| Whether CFA claims are within Tucker Act jurisdiction | CFA provides the substantive money rights | CFA money damages are for qui tam plaintiffs in district courts | Lack of jurisdiction; CFA claims not within CFC scope |
| Transfer to another court in the interest of justice | Not specifically requested, but transfer should be considered | Not in the interest of justice given prior similar Florida case | Transfer denied |
| Equal protection claim as money-mandating | Equal protection claim exists | Not money-mandating under Fourteenth Amendment | Dismissed for lack of jurisdiction |
| Effect of prior Florida action on transfer | N/A | Prior dismissal shows frivolousness; transfer inappropriate | Not in the interest of justice to transfer |
Key Cases Cited
- Folden v. United States, 379 F.3d 1344 (Fed. Cir. 2004) (subject-matter jurisdiction; pleadings analyzed on face of complaint)
- Metabolite Labs., Inc. v. Lab. Corp. of Am. Holdings, 370 F.3d 1354 (Fed. Cir. 2004) (jurisdictional inquiry; pleadings taken as true)
- Shearin v. United States, 992 F.2d 1195 (Fed. Cir. 1993) (jurisdiction; face-of-pleadings standard)
- Haines v. Kerner, 404 U.S. 519 (U.S. Supreme Court 1972) (pro se pleading standards; liberal construction)
- Jan’s Helicopter Serv., Inc. v. Fed. Aviation Admin., 525 F.3d 1299 (Fed. Cir. 2008) (requirement of independent money-mandating right)
- Schweitzer v. United States, 82 F.1d 592 (Fed. Cl. 2008) (qui tam CFA claims; jurisdictional limitations)
- LeBlanc v. United States, 50 F.3d 1025 (Fed. Cir. 1995) (qui tam, money-mandating rights limitations)
- Moore v. Pub. Defenders Office, 76 Fed.Cl. 617 (Fed. Cl. 2007) (no jurisdiction over state/local entities)
- Stephenson v. United States, 58 Fed.Cl. 186 (Fed. Cl. 2003) (jurisdiction over non-federal entities)
- Tex. Peanut Farmers v. United States, 409 F.3d 1370 (Fed. Cir. 2005) (possibility of sua sponte transfer; intervening jurisdictional issues)