Harris v. United States, 15-1026

Plaintiff Jermaine A. Harris, convicted in Florida state court of first-degree murder in 1998 and sentenced to life, remains incarcerated; his convictions were affirmed in 1999.
In 2015 Harris sued the United States and the State of Florida in the Court of Federal Claims, alleging state trial judges, prosecutors, and investigators never took their oaths of office and therefore acted without authority.
Harris sought $20 million and asserted numerous federal and state crimes and constitutional violations (Fifth, Sixth, Fourteenth Amendments; various federal statutes) and argued the United States was defrauded by the state officials.
The government moved to dismiss for lack of subject-matter jurisdiction under RCFC 12(b)(1), arguing (1) claims against Florida or its agents are outside the Court of Federal Claims, (2) Harris failed to identify a money‑mandating source that would support Tucker Act jurisdiction, and (3) any claim tied to his criminal case is time‑barred.
Harris responded by invoking various statutes, regulations, and constitutional provisions (including the False Claims Act and federal oath statutes) and asked that any non‑cognizable claims be transferred to a proper court under 28 U.S.C. § 1631.
The Court granted the government's motion, holding Harris' claims are either against the State of Florida (outside the court's jurisdiction), not based on money‑mandating sources attributable to the United States, and that transfer was not appropriate.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Jurisdiction over claims against state actors	Harris argued Florida officials were "agents" of the U.S. and thus within the Court of Federal Claims' jurisdiction	U.S. argued claims against states or their agents are outside this court's jurisdiction	Dismissed: claims against Florida or its agents are not cognizable in this court
Tucker Act money‑mandating source	Harris pointed to constitutional provisions, federal regulations, and the False Claims Act as mandating payment	U.S. argued plaintiff failed to identify a law that fairly mandates compensation by the U.S.	Dismissed: no money‑mandating source tied to the United States identified
Ability to bring claims on behalf of the U.S. (qui tam / False Claims Act theory)	Harris asserted the U.S. was defrauded and sought to vindicate federal rights	U.S. argued a private plaintiff cannot convert a claim on behalf of the government into a claim against the government in this court; qui tam suits belong in district court	Dismissed: claim on behalf of the U.S. does not create a claim against the U.S. in this forum
Transfer of non‑cognizable claims under § 1631	Harris requested transfer of any claims outside the court's jurisdiction	U.S. argued transfer inappropriate given defects and unclear proper forum	Denied: court declined transfer because it could not identify a proper transferee or show transfer would serve justice

Scheuer v. Rhodes, 416 U.S. 232 (establishes that, for certain motions, courts accept plaintiff's factual allegations as true)
United States v. Mitchell, 463 U.S. 206 (explains Tucker Act requires a money‑mandating source that can fairly be interpreted as mandating compensation)
McNutt v. General Motors Acceptance Corp., 298 U.S. 178 (plaintiff bears burden of establishing jurisdiction by a preponderance of the evidence)
Fisher v. United States, 402 F.3d 1167 (Tucker Act jurisdiction requires an independent source of substantive law creating right to money damages)
Souders v. South Carolina Public Service Authority, 497 F.3d 1303 (Court of Federal Claims lacks jurisdiction over claims against states or their agents)
Jan's Helicopter Service, Inc. v. Federal Aviation Administration, 525 F.3d 1299 (Fifth Amendment may be money‑mandating when a taking by the United States is alleged)