Metzinger v. Department of Veterans Affairs
20 F.4th 778
| Fed. Cir. | 2021Background
- Dr. Rebecca Metzinger sued the Department of Veterans Affairs in the Eastern District of Louisiana under the Equal Pay Act (EPA), seeking more than $10,000 in damages.
- The government moved to dismiss for lack of subject-matter jurisdiction, arguing that the Tucker Act vests exclusive jurisdiction in the Court of Federal Claims for claims against the United States exceeding $10,000.
- The district court concluded it lacked jurisdiction and, under 28 U.S.C. § 1631, transferred the EPA claim to the Court of Federal Claims.
- Metzinger appealed the transfer to the Federal Circuit (and separately had an appeal docketed in the Fifth Circuit that was dismissed); the parties disputed whether district courts retained § 1331 federal-question jurisdiction for such claims.
- The Federal Circuit held that under controlling precedent—especially Abbey v. United States—district courts lack subject-matter jurisdiction over FLSA/EPA money-damages claims against the federal government that exceed $10,000, and affirmed the § 1631 transfer to the Court of Federal Claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a district court has subject-matter jurisdiction over an EPA (FLSA) money-damages claim against the federal government exceeding $10,000. | Metzinger: § 1331 federal-question jurisdiction makes the district court a “court of competent jurisdiction” under § 216(b); Abbey did not hold district courts lack jurisdiction. | Government: Tucker Act (and precedent) supplies exclusive forum for >$10,000 claims—Court of Federal Claims (Little Tucker Act limits district courts to ≤ $10,000). | Held: District courts lack jurisdiction for such claims; the Court of Federal Claims has jurisdiction. |
| Whether the district court properly transferred the case under 28 U.S.C. § 1631 rather than dismissing. | Metzinger: she would accept transfer if district court lacked jurisdiction. | Government: transfer was an appropriate remedy if district court lacked jurisdiction. | Held: Transfer under § 1631 was proper because the transferor lacked jurisdiction and the transferee (CFC) had it; no abuse of discretion. |
| Whether Abbey means only that the Court of Federal Claims has jurisdiction, or that it is the exclusive forum for FLSA/EPA claims > $10,000. | Metzinger: Abbey only established that the CFC has jurisdiction, not that district courts are precluded. | Government: Abbey and prior precedent establish the Tucker Act is the only source of jurisdiction for such claims, making CFC exclusive for >$10,000. | Held: Abbey is read to mean the Tucker Act is the sole identified source of jurisdiction for these government FLSA/EPA claims, so the CFC (or district court only for ≤ $10,000) is the proper forum. |
| Whether the Supreme Court’s decision in Bormes displaced the Tucker Act framework for FLSA/EPA claims against the government. | Metzinger: Bormes could allow reading § 216(b) with § 1331 to preserve district-court jurisdiction. | Government: Bormes is distinguishable; FLSA does not specify a conflicting forum that displaces the Tucker Act. | Held: Bormes is distinguished—because the FLSA lacks a precise statutory forum specification, it does not supplant Tucker Act jurisdiction. |
Key Cases Cited
- Abbey v. United States, 745 F.3d 1363 (Fed. Cir. 2014) (held Tucker Act/Court of Federal Claims has jurisdiction over FLSA/EPA money-damages claims against the government; FLSA does not displace Tucker Act)
- Zumerling v. Devine, 769 F.2d 745 (Fed. Cir. 1985) (court held district courts’ jurisdiction over FLSA claims against the government is limited by the Little Tucker Act’s $10,000 cap)
- Saraco v. United States, 61 F.3d 863 (Fed. Cir. 1995) (reaffirmed Zumerling that Tucker Act supplies jurisdiction for government FLSA claims)
- Bormes v. United States, 568 U.S. 6 (2012) (held that a statute’s detailed remedial scheme can displace the Tucker Act’s gap-filling jurisdiction)
- Fisherman’s Harvest, Inc. v. PBS & J, 490 F.3d 1371 (Fed. Cir. 2007) (transfer under § 1631 requires transferor lack jurisdiction and transferee have it)
- Rick’s Mushroom Serv., Inc. v. United States, 521 F.3d 1338 (Fed. Cir. 2008) (review standard for abuse of discretion when a court chooses to transfer under § 1631 versus dismissing)
- FDIC v. Meyer, 510 U.S. 471 (1994) (sovereign immunity bars suit against the United States absent waiver)