Kornafel v. United States, 20-1655

On March 11, 1992 a USPS vehicle collided with Stanley Kornafel’s car; a USPS employee allegedly orally agreed to pay $1,000 for damages.
Kornafel sued the United States in the Eastern District of Pennsylvania on February 25, 1994; the parties reached a settlement on July 14, 1995 that Kornafel contends was forced and unpaid.
Kornafel’s attorney sent a December 3, 1995 letter indicating Kornafel had not signed the settlement; Kornafel alleges this and other events show a conspiracy/fraud preventing recovery.
Over the next ~25 years Kornafel filed numerous district-court actions about the same accident, all dismissed; he filed a complaint in the Court of Federal Claims on November 16, 2020 asserting breach of contract, constitutional violations, and conspiracy.
The government moved to dismiss under RCFC 12(b)(1), arguing all events fixing liability occurred by December 1995 and the Tucker Act’s six-year limitations period (28 U.S.C. § 2501) therefore bars the suit; the government also argued the CFC cannot review district-court rulings.
The Court granted the government’s motion: Kornafel’s claims accrued by 1995 (or at latest 1996), are time-barred, and many asserted claims lie outside the CFC’s money‑mandating jurisdiction (and the CFC cannot reexamine district-court decisions).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Statute of limitations / Tucker Act accrual	Claim is timely because government’s fraud/conspiracy is ongoing	All events fixing liability occurred by Dec 1995; §2501 six‑year bar applies	Dismissed for lack of jurisdiction: claim accrued by 1995 and is time‑barred
Continuing‑claim doctrine / tolling	Repeated dismissals and continuing fraud tolled accrual	Single accident is one distinct event; doctrine inapplicable	Continuing‑claim doctrine does not apply to a single event; accrual not tolled
Review of district‑court rulings	Seeks review of prior district‑court decisions as part of relief	CFC lacks authority to review decisions of other federal courts	CFC cannot reexamine district court decisions; no jurisdiction to do so
Constitutional claims / money‑mandating	Alleges violations of 1st, 13th, and 14th Amendments and due process	These constitutional provisions do not mandate money damages against the U.S.	CFC lacks jurisdiction over these constitutional claims (not money‑mandating)
Tort claims	Asserts tort recovery for vehicle collision	Tucker Act excludes torts; tort claims belong in district court	CFC has no jurisdiction over tort claims; they must be litigated in district court

Smith v. United States, 709 F.3d 1114 (Fed. Cir. 2013) (Tucker Act requires a separate money‑mandating source)
United States v. Mitchell, 463 U.S. 206 (U.S. 1983) (statute or source must fairly be read to mandate compensation)
United States v. Testan, 424 U.S. 392 (U.S. 1976) (Tucker Act does not by itself create money‑mandating rights)
United States v. White Mountain Apache Tribe, 537 U.S. 465 (U.S. 2003) (statutory source must be reasonably amenable to a damages remedy)
John R. Sand & Gravel Co. v. United States, 552 U.S. 130 (U.S. 2008) (§ 2501 statute of limitations is jurisdictional)
Hopland Band of Pomo Indians v. United States, 855 F.2d 1573 (Fed. Cir. 1988) (accrual occurs when events fixing liability have happened and plaintiff knows or should know)
Brown Park Estates-Fairfield Dev. v. United States, 127 F.3d 1449 (Fed. Cir. 1997) (continuing‑claim doctrine applies only where claim is divisible into discrete wrongs)
Innovair Aviation Ltd. v. United States, 632 F.3d 1336 (Fed. Cir. 2011) (CFC lacks jurisdiction to review other federal courts’ decisions)
Vereda Ltda. v. United States, 271 F.3d 1367 (Fed. Cir. 2001) (CFC cannot entertain claims requiring scrutiny of another tribunal’s actions)
Joshua v. United States, 17 F.3d 378 (Fed. Cir. 1994) (CFC lacks jurisdiction to review district court or clerk actions)
Haines v. Kerner, 404 U.S. 519 (U.S. 1972) (pro se pleadings held to less stringent standards, but jurisdictional requirements remain)