Morgan v. United States, 16-1661

Plaintiff Lewis Rudolph Morgan, pro se, sued to challenge a Washington state court forfeiture proceeding and a subsequent state-court award of $1,931 in costs and attorney fees against him.
After exhausting state-court appeals, Morgan filed a complaint in the U.S. Court of Federal Claims seeking review of the state orders and various equitable remedies (lien, injunction) and alleging wrongful acts by private parties and the state courts.
The United States did not answer the complaint, but the Court considered jurisdiction sua sponte.
The Court analyzed whether it had Tucker Act jurisdiction to grant the requested relief and whether Morgan had identified a separate source of substantive law entitling him to money damages from the United States.
The Court found Morgan alleged state-court errors and private-party torts, not a claim against the United States or a money-mandating source; non-monetary equitable relief was not collateral to any money judgment.
The Court dismissed the complaint for lack of subject-matter jurisdiction and noted the filing fee remained unpaid.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether CFC has jurisdiction under the Tucker Act	Morgan seeks review of state-court orders and equitable relief; implies U.S. responsibility	(Not answered) Court evaluates jurisdiction sua sponte	Dismissed: no Tucker Act jurisdiction because no money-mandating source alleged
Whether federal courts may review state-court judgments	Morgan asks the CFC to overturn state-court fee award	N/A — federal courts lack authority to review state-court final judgments	Held: lower federal courts cannot review state high-court decisions; only SCOTUS may review state supreme court via §1257
Whether claims against private parties/state courts constitute claims against the U.S.	Morgan alleges illegal seizures by private parties and misconduct by state courts	Such allegations do not make the U.S. a proper defendant under the Tucker Act	Dismissed: claims are not against the United States and, if they were, sound in tort outside CFC jurisdiction
Whether the Court can grant equitable relief (lien/injunction) absent money judgment	Morgan requests special lien and injunction on property/contract	Equitable relief is available only as incident to a money judgment under Tucker Act	Denied: no money claim pleaded, so equitable relief unavailable

United States v. Testan, 424 U.S. 392 (recognizing Tucker Act does not by itself create money-mandating substantive rights)
Steel Co. v. Citizens for a Better Env't, 523 U.S. 83 (jurisdiction is threshold and must be established)
Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (federal courts cannot sit in direct review of state-court judgments)
Henke v. United States, 60 F.3d 795 (Fed. Cir. 1995) (pro se pleadings are construed liberally but cannot cure jurisdictional defects)
James v. Caldera, 159 F.3d 573 (Fed. Cir. 1998) (equitable relief under the Tucker Act is limited to that which is incident to a money judgment)