Labatte v. United States
16-798
| Fed. Cl. | Jul 28, 2017Background
- Keepseagle was a class settlement resolving alleged USDA discrimination by creating a non-judicial claims process (Track A/Track B) whose determinations were declared "final and not reviewable" by any court.
- Timothy LaBatte, a class member, submitted a Track B claim (documents and unsigned declarations from two BIA employees) and his claim was denied by a Track B Neutral as failing the Settlement's evidentiary requirements.
- LaBatte alleged the Government instructed his potential witnesses (BIA employees) not to sign declarations and later asserted breach of the Settlement Agreement and the covenant of good faith and fair dealing, seeking $202,700.52.
- He sought relief first in the D.D.C. Keepseagle case (motion to intervene) — denied — and the D.C. Circuit affirmed that the district court lacked ancillary jurisdiction to hear his breach claim because of the Settlement's finality clause.
- LaBatte then sued in the Court of Federal Claims alleging breach by the United States; the Government moved to dismiss for lack of subject-matter jurisdiction and failure to state a claim.
- The Court of Federal Claims held LaBatte knowingly waived judicial review of Track B determinations under the Settlement and dismissed for lack of jurisdiction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Court of Federal Claims has jurisdiction to review the Track B denial | LaBatte: Government interference in the claims process breached the Settlement and deprived him of process, so judicial relief available | U.S.: Settlement expressly bars judicial review of claim determinations; Court lacks jurisdiction | Held: No jurisdiction — LaBatte waived judicial review; finality clause controls |
| Whether the Government breached the Settlement by allegedly directing witnesses not to sign | LaBatte: Government misconduct prevented essential evidence and breached implied covenant of good faith | U.S.: Government had no role in the Non-Judicial Process; no breach and claim determinations remain final | Held: Court did not reach merits because jurisdiction is lacking due to finality waiver |
| Whether the Tucker Act supplies a money-mandating source permitting suit | LaBatte: Tucker Act permits contract/damages claims against the United States | U.S.: No independent money-mandating source because parties contracted away judicial review | Held: Tucker Act jurisdiction not available here because plaintiff agreed to final, non-reviewable process |
| Whether any other forum or enforcement clause permits relief in this court (e.g., 45-day notice) | LaBatte: Government failed to respond within 45 days to notice of violation; seeks relief | U.S.: Settlement grants enforcement authority over distribution only to the district court; claim determinations final | Held: Enforcement authority lies with the district court per the Settlement; CFC lacks jurisdiction to reopen determinations |
Key Cases Cited
- United States v. Sherwood, 312 U.S. 584 (sovereign immunity requires consent to suit)
- Todd v. United States, 386 F.3d 1091 (Fed. Cir.) (Tucker Act requires an independent money-mandating source)
- Monsanto Co. v. McFarling, 302 F.3d 1295 (Fed. Cir.) (forum-selection/enforceability principles)
- Minesen Co. v. McHugh, 671 F.3d 1332 (Fed. Cir.) (government can enforce contractual forum waivers)
- Burger King Corp. v. Rudzewicz, 471 U.S. 462 (forum-selection clauses enforceable unless unreasonable)
- Town of Newton v. Rumery, 480 U.S. 386 (parties may waive statutory or constitutional rights by contract)
- Ford-Clifton v. Dep't of Veterans Affairs, 661 F.3d 655 (Fed. Cir.) (enforcing finality clauses in settlements)
- Panduit Corp. v. HellermannTyton Corp., 451 F.3d 819 (Fed. Cir.) (effect of settlement finality)
- In re Dept. of Energy Stripper Well Exemption Litig., 846 F.2d 756 (enforcing arbitration/finality provisions)
- Goodsell v. Shea, 651 F.2d 765 (enforcing agreement not to appeal certain administrative decisions)
- United States v. Armour & Co., 402 U.S. 673 (consent decrees/finality waivers enforced)
- W.R. Grace & Co. v. Local Union 759, 461 U.S. 757 (collective bargaining clause enforcing final and unappealable arbitration)