Lawton v. United States
621 F. App'x 671
Fed. Cir.2015Background
- Plaintiff Ni-Shon Latia Lawton sued in the Court of Federal Claims seeking $3,000,000 and injunctive relief for alleged stalking, document forgery, harassment, and a fraudulent eviction tied to prior child-custody litigation.
- Complaint named the United States but primarily alleged wrongdoing by New Jersey state agencies, state officials, HHS-associated individuals, and private parties.
- Claims asserted included constitutional violations, civil and criminal law violations, and torts, described as retaliatory acts for a previous lawsuit.
- The Court of Federal Claims dismissed the complaint sua sponte for lack of subject-matter jurisdiction under the Tucker Act.
- Lawton appealed the dismissal to the Federal Circuit; the appeal raises whether the Claims Court had jurisdiction over the pleaded claims and defendants.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Court of Federal Claims has jurisdiction over Lawton's suit | Lawton contended naming the United States made it the proper defendant and argued New Jersey is "territory claimed by the U.S.," so state acts can be attributed to the U.S. | The Claims Court lacks jurisdiction because allegations target state actors and private parties and do not invoke a money-mandating federal source | Court affirmed dismissal for lack of jurisdiction; Tucker Act prerequisites not met |
| Whether claims for constitutional and civil-rights violations are within Tucker Act | Lawton sought damages for constitutional violations | United States argued constitutional and civil-rights claims here do not arise from a separate money-mandating source required by the Tucker Act | Claims dismissed: constitutional/civil-rights claims not within Claims Court jurisdiction |
| Whether tort and criminal-code allegations are actionable in Claims Court | Lawton alleged torts and criminal violations against state/private actors | United States maintained Claims Court does not hear tort or criminal claims against non-federal defendants under the Tucker Act | Dismissed: tort and criminal allegations outside Claims Court jurisdiction |
| Whether naming the United States in caption suffices to establish jurisdiction | Lawton relied on caption naming and territorial theory | United States/Claims Court held mere captioning cannot convert state/private misconduct into a claim against the U.S. without a money-mandating source | Caption alone insufficient; jurisdictional defect affirmed |
Key Cases Cited
- M. Maropakis Carpentry, Inc. v. United States, 609 F.3d 1323 (Fed. Cir. 2010) (standard of review: de novo for jurisdictional dismissal)
- Reynolds v. Army & Air Force Exch. Serv., 846 F.2d 746 (Fed. Cir. 1988) (plaintiff bears burden to prove jurisdiction by preponderance)
- United States v. Sherwood, 312 U.S. 584 (1941) (Claims Court jurisdiction limited to suits against the United States)
- Fisher v. United States, 402 F.3d 1167 (Fed. Cir. 2005) (plaintiff must identify a separate, money-mandating source of law to invoke Tucker Act)
- Joshua v. United States, 17 F.3d 378 (Fed. Cir. 1994) (Claims Court lacks jurisdiction over tort and criminal-code claims against non-federal defendants)