Robinson v. United States, 17-745

Background

Pro se plaintiff Taveren Robinson, incarcerated at SCI‑Greene, filed a civil complaint (breach of contract, Thirteenth Amendment/involuntary servitude, and related claims) naming Robert Gilmore (SCI‑Greene superintendent) and the United States/State of Pennsylvania and seeks ~$324,500.
Plaintiff attached four self‑prepared documents he labels as contract formation/acceptance evidence; most are signed only by Robinson.
Plaintiff asserted jurisdiction under various statutes (28 U.S.C. §§ 3001, 3002; 5 U.S.C. §§ 2104–2105) and the Thirteenth Amendment.
The Court of Federal Claims reviewed jurisdiction sua sponte and treated the suit as one against the United States for jurisdictional analysis.
The court found no money‑mandating source or valid contract with the United States, concluded it lacks subject‑matter jurisdiction, and declined to transfer the case to the district court because a substantially similar action was already pending in the Western District of Pennsylvania. The complaint was dismissed without prejudice; IFP was granted.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether statutory or constitutional sources invoked provide Tucker Act jurisdiction	Robinson invoked 28 U.S.C. §§ 3001, 3002 and 5 U.S.C. §§ 2104–2105 and the Thirteenth Amendment as a basis for money damages	The statutes cited are not money‑mandating for Tucker Act purposes and the Thirteenth Amendment does not mandate money damages	Court: No jurisdiction — cited statutes are not money‑mandating and the Thirteenth Amendment does not confer jurisdiction in this court
Whether claims against a state prison official are within this court's jurisdiction	Robinson treats Gilmore’s alleged silence/inaction as creating contractual liability and federal exposure	Court: Claims against individuals/state officials are not cognizable in the Court of Federal Claims absent a money‑mandating source against the United States	Held: Claims against Gilmore (and state actors) are outside this court’s jurisdiction
Whether documents attached constitute a contract binding the United States	Robinson contends his notices/affidavits create a contract and acceptance by silence, binding the United States and Pennsylvania to pay	Court: The exhibits are unsigned by any U.S. official, lack mutual intent, consideration, clear offer/acceptance, and actual authority to bind the government	Held: Allegations of a contract are frivolous and insufficient to establish Tucker Act jurisdiction
Whether transfer under 28 U.S.C. § 1631 is appropriate	Robinson did not oppose transfer; seeks relief for unlawful detention which he also pursues in district court	Government implicitly argues district court already has related litigation; court must consider interest of justice	Held: Transfer denied — similar action already pending in the Western District of Pennsylvania, so transfer is not in the interest of justice

Key Cases Cited

Kroll v. Finnerty, 242 F.3d 1359 (Fed. Cir. 2001) (jurisdictional claims that are "attenuated and unsubstantial" may be dismissed)
Hagans v. Lavine, 415 U.S. 528 (1974) (standard for frivolous or insubstantial federal jurisdiction claims)
Scheuer v. Rhodes, 416 U.S. 232 (1974) (pro se allegations must be taken as true for jurisdictional inquiry)
United States v. Testan, 424 U.S. 392 (1976) (Tucker Act requires a money‑mandating source separate from the Act itself)
Eastport S.S. Corp. v. United States, 372 F.2d 1002 (Ct. Cl. 1967) (money‑mandating test for Tucker Act jurisdiction)
United States v. Mitchell, 463 U.S. 206 (1983) (distinguishing jurisdiction and substantive waiver under the Tucker Act)