Morgan v. United States, 132 Fed. Cl. 2

Pro se plaintiff Lewis R. Morgan filed a document treated as a complaint seeking transfer of an Oregon state-court matter to the U.S. Court of Federal Claims and later filed an amended complaint.
Morgan alleged breaches of contract and wrongful acts by the State of Oregon, Linn County Federal Credit Union, and Hartford Casualty Insurance Group concerning his vehicle, assets, and family (including an asserted ransom).
The amended complaint sought declaratory and injunctive relief under 28 U.S.C. §§ 2201–2202 and asserted various claims including contract breaches and IP infringement, but did not allege claims against the United States as the responsible actor.
The Court of Federal Claims reviewed subject-matter jurisdiction sua sponte and applied liberal standards for pro se pleadings while noting the plaintiff still bears the burden to establish jurisdiction.
The court concluded it lacked jurisdiction because the Tucker Act permits suits only against the United States and Morgan’s allegations targeted state actors and private parties, not the federal government.
The complaint was dismissed without prejudice and each party was to bear its own costs.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Court of Federal Claims has subject-matter jurisdiction under the Tucker Act	Morgan sought transfer and relief in this Court for alleged state and private-actor wrongs; invoked declaratory relief under §§ 2201–2202	The United States (as the only proper defendant in this court) did not commit the alleged acts; claims target state and private parties and thus fall outside this court’s jurisdiction	Court held it lacks jurisdiction under the Tucker Act because the allegations are against state and private actors, not the United States; dismissal without prejudice
Whether pro se status relaxes jurisdictional burden	Morgan relied on pro se status and liberal pleading standards	Court acknowledged leniency but emphasized plaintiff still must prove jurisdictional requirements	Court applied leniency for pleading formalities but dismissed because plaintiff failed to meet jurisdictional requirements
Whether the complaint asserted a separate substantive source of law creating a right to money damages against the U.S.	Morgan invoked declarations and various causes of action but did not identify a substantive federal source creating money-claims against the U.S.	The Tucker Act requires a separate substantive source of law for money damages against the U.S.; none was pleaded	Court held plaintiff failed to identify a separate source of law that would waive sovereign immunity and confer jurisdiction

Rick's Mushroom Serv., Inc. v. United States, 521 F.3d 1338 (Fed. Cir. 2008) (court may inquire into jurisdictional facts and Tucker Act jurisdiction principles)
Jan's Helicopter Serv., Inc. v. Fed. Aviation Admin., 525 F.3d 1299 (Fed. Cir. 2008) (Tucker Act does not create substantive causes of action; plaintiff must identify separate source of law for money damages)
Arbauch v. Y & H Corp., 546 U.S. 500 (2006) (courts have an independent obligation to determine subject-matter jurisdiction)
Haines v. Kerner, 404 U.S. 519 (1972) (pro se complaints are held to less stringent standards)
United States v. Sherwood, 312 U.S. 584 (1941) (the United States is the proper defendant in the Court of Federal Claims for Tucker Act matters)
Fisher v. United States, 402 F.3d 1167 (Fed. Cir. 2005) (en banc) (need for a separate source of substantive law to create a right to money damages against the United States)