Maldonado v. United States, 17-813

Background

Plaintiff Fernando Maldonado, proceeding pro se, sued alleging constitutional, statutory, and state-law violations arising from the New York State Division of Human Rights' handling of an employment-discrimination matter and sought money, declaratory, and injunctive relief.
Maldonado referenced claims under the Commerce Clause, Supremacy Clause, the Fifth Amendment Due Process Clause, 42 U.S.C. § 1983, the Declaratory Judgment Act, and unspecified New York law.
He previously litigated related claims in the Southern District of New York; that court dismissed aspects of his suit on sovereign-immunity/Eleventh Amendment grounds.
The United States moved to dismiss for lack of subject-matter jurisdiction under RCFC 12(b)(1), arguing the Court of Federal Claims (CFC) lacks jurisdiction over state agencies and certain causes of action.
The CFC analyzed whether Maldonado identified a money-mandating source of law under the Tucker Act (28 U.S.C. § 1491) and whether the court may award equitable relief or hear § 1983 and state-law claims.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the CFC has jurisdiction over claims against the NYSDHR (a state agency)	Maldonado contended the NYSDHR's actions violated constitutional and statutory rights and the CFC should adjudicate them	The United States argued Tucker Act jurisdiction extends only to claims against the United States, not state agencies	Dismissed — CFC lacks jurisdiction over state agencies like NYSDHR; claims against NYSDHR are outside § 1491(a)(1) jurisdiction
Whether constitutional provisions alleged (Commerce Clause, Supremacy Clause, Due Process) are money-mandating	Maldonado sought money damages under those constitutional provisions	Government maintained those provisions do not by themselves mandate money damages and thus cannot create Tucker Act jurisdiction	Dismissed — constitutional provisions cited are not money-mandating and do not provide a Tucker Act basis
Whether § 1983 claims can be heard in the CFC	Maldonado invoked § 1983 for civil-rights relief	Government argued § 1983 jurisdiction is vested exclusively in district courts, not the CFC	Dismissed — § 1983 claims belong in federal district courts; CFC lacks jurisdiction
Whether Declaratory/Equitable relief and supplemental state-law claims lie in the CFC	Maldonado sought declaratory/injunctive relief and invoked supplemental jurisdiction for state-law claims	Government argued the CFC generally lacks authority to grant broad equitable relief and cannot hear state-law claims under Tucker Act; § 1367 applies to district courts	Dismissed — CFC cannot grant general declaratory/injunctive relief absent specific statutory authorization; state-law claims are outside CFC jurisdiction

Key Cases Cited

United States v. Sherwood, 312 U.S. 584 (statutory limits on Court of Claims jurisdiction)
United States v. Mitchell, 463 U.S. 206 (Tucker Act waives sovereign immunity but does not create substantive money-mandating rights)
United States v. Testan, 424 U.S. 392 (Tucker Act requires separate money-mandating source)
Eastport S.S. Corp. v. United States, 372 F.2d 1002 (Cl. Ct.) (money-mandating standard)
United States v. Connolly, 716 F.2d 882 (Fed. Cir.) (constitutional provisions are not inherently money-mandating)
LeBlanc v. United States, 50 F.3d 1025 (Fed. Cir.) (Fifth Amendment Due Process clause is not money-mandating)
Trevino v. United States, 113 Fed. Cl. 204 (CFC lacks jurisdiction to review other federal courts and certain constitutional claims)