Raven v. United States, 16-1682

Pro se plaintiff Julian Marcus Raven sued numerous federal officials, the National Portrait Gallery, and Congress in the Court of Federal Claims seeking relief for various alleged constitutional and statutory violations.
Raven moved to transfer the case to the U.S. District Court for the District of Columbia under 28 U.S.C. § 1631, contending this Court lacks subject-matter jurisdiction.
The Court of Federal Claims has limited jurisdiction under the Tucker Act to money-mandating claims against the United States.
Raven’s complaint asserted claims under a mix of statutes and constitutional provisions (including the APA and First Amendment) and sought punitive damages and civil-rights relief under 42 U.S.C. § 1983.
The government did not oppose transfer and acknowledged Raven’s APA-based allegations involve actions in D.C., a proper forum for those claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does the Court of Federal Claims have subject-matter jurisdiction?	Raven contends the Court lacks jurisdiction and asks for transfer.	Gov’t did not contest lack of jurisdiction over Raven’s principal claims.	Court lacks jurisdiction over most claims (Tucker Act limits apply).
Are Raven’s § 1983 and punitive-damages claims cognizable here?	Raven included § 1983 and punitive damages in his pleadings.	Such claims are reserved for district courts and punitive damages sound in tort.	§ 1983 claims and punitive damages are outside this Court’s jurisdiction.
Do Raven’s First Amendment and other cited statutes invoke money-mandating relief?	Raven cited multiple statutes and constitutional provisions.	The listed statutes and First Amendment are not money‑mandating.	Those provisions do not confer jurisdiction here.
Should the case be transferred to D.D.C. under 28 U.S.C. § 1631?	Transfer is appropriate because claims (e.g., APA) could have been brought in D.C.	Gov’t took no position on transfer; acknowledged APA claims fit district court.	Transfer to the U.S. District Court for the District of Columbia granted as in the interest of justice.

United States v. Testan, 424 U.S. 392 (explaining Tucker Act jurisdictional limits)
Eastport Steamship Corp. v. United States, 372 F.2d 1002 (clarifying Court of Federal Claims’ jurisdictional scope)
Rodriguez v. United States, 862 F.2d 1558 (standards for transfer under § 1631)
Albino v. United States, 104 Fed. Cl. 801 (application of § 1631 transfer factors)
Stephenson v. United States, 58 Fed. Cl. 186 (only United States is proper defendant in Court of Federal Claims)
Jefferson v. United States, 104 Fed. Cl. 81 (district courts have exclusive jurisdiction over civil‑rights claims)
Marlin v. United States, 63 Fed. Cl. 475 (same re: civil‑rights jurisdiction)
Thompson v. United States, 229 Ct. Cl. 789 (punitive damages sound in tort, outside Tucker Act jurisdiction)
United States v. Connolly, 716 F.2d 882 (First Amendment is not money‑mandating)
LeBlanc v. United States, 50 F.3d 1025 (Court of Federal Claims limited to money‑mandating constitutional provisions)
Auto Europe, LLC v. Conn. Indem. Co., 321 F.3d 60 (interpretation of “interest of justice” for transfers)
Galloway Farms, Inc. v. United States, 834 F.2d 998 (no transfer when claim fails on the merits)
Zinger Constr. Co. v. United States, 753 F.2d 1053 (transfer principles under § 1631)
Faulkner v. United States, 43 Fed. Cl. 54 (transfer inappropriate when futile)
Siegal v. United States, 38 Fed. Cl. 386 (same)
Ashcroft v. Iqbal, 556 U.S. 662 (plausibility standard for factual allegations)