Mata v. United States
107 Fed. Cl. 618
Fed. Cl.2012Background
- Mata, a former Army engineer, sues the United States Army for breach of a Negotiated Settlement Agreement (NSA) related to whistleblower–related grievances under Title VII.
- NSA June 20, 2007 required an independent review of Mata’s 2006 evaluation and reprimand, a good-faith attempt to transfer him laterally, and nullification of pre-NSA actions.
- Mata notified the Army of noncompliance with the NSA on August 30, 2007, triggering further proceedings under the NSA terms.
- Col. Casias issued an independent review (Nov 1, 2007) recommending improvement of Mata’s rating, removal of the reprimand, and transfer as quickly as possible, but Army actions were limited by vacancies.
- The EEOCCR and EEOC ultimately found no breach, Mata appealed, and the case was transferred from Texas federal court to the Court of Federal Claims before Mata filed the present breach claim in this court.
- Mata seeks monetary damages (lost wages, back/front pay, and attorney’s fees) alleging multiple NSA breaches; the Government moves to dismiss for lack of jurisdiction, arguing the NSA isn’t money-mandating.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Tucker Act jurisdiction lies for a breach of the NSA seeking monetary damages | Mata: NSA breach inherently supports money damages | Mata's claim is not money-mandating under the NSA | Jurisdiction exists; NSA can be interpreted as money-damaging in relation to Mata's future employment |
| Whether Holmes v. United States governs money-damating interpretation | Holmes supports money damages where contract relates to future employment | Holmes limits do not apply to Mata | Holmes framework applied; NSA can be read to contemplate monetary compensation via future employment |
| Whether the NSA language restricting remedies precludes money damages | No explicit limitation on remedies defeats preclusion | Paragraph 5 language shows no money damages remedy | NSA language does not preclude money damages; jurisdiction confirmed |
Key Cases Cited
- Holmes v. United States, 657 F.3d 1303 (Fed. Cir. 2011) (money-mandating default in contracts; can imply monetary relief from future employment relations)
- Mastrolia v. United States, 91 Fed.Cl. 369 (Fed. Cl. 2010) (damages remedy presumed for breach of contract)
- Patterson v. United States, 84 Fed.Cl. 583 (Fed. Cl. 2008) (breach of contract damages in Federal Claims context)
- Brizuela v. United States, 103 Fed.Cl. 635 (Fed. Cir. 2012) (reinstatement/consideration could relate to future employment)
- San Juan City College v. United States, 391 F.3d 1357 (Fed. Cir. 2004) (contracts generally do not specify damages, but can imply monetary relief in context)
- Sanders v. United States, 252 F.3d 1329 (Fed. Cir. 2001) (damages as remedy in contract-related disputes with government)