Roxann Franklin Mason v. Raymond Mabus, Jr.
408 U.S. App. D.C. 319
| D.C. Cir. | 2014Background
- Franklin-Mason and Navy settled Title VII dispute in 2001; settlement allowed judicial enforcement and damages for breach.
- Settlement contemplated creation of a Naval Fleet Auxiliary Force program and a Senior Financial Analyst role, which were never approved.
- Franklin-Mason claimed the Navy breached by not implementing the terms and sought nearly $900,000 in damages and fees.
- The district court initially retained jurisdiction; later, transfer and multiple back-and-forth rulings occurred among the district court and the Court of Federal Claims.
- The two questions on appeal: (a) sovereign immunity waiver for damages >$10,000; (b) whether a consent-decree settlement is a contract under the Tucker Act and the proper forum for enforcement.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether district court has sovereign-immunity waiver for breach damages over $10,000 | Franklin-Mason argues Tucker Act/Kokkonen divestment; waiver exists | Navy argues no waiver; Tucker Act exclusive to CFC for >$10,000 | No waiver; Kokkonen does not create one. |
| Whether a consent decree settlement is a contract under the Tucker Act and falls within CFC jurisdiction | Settlement is a contract; CFC proper forum for enforcement | Consent decree not a contract under Tucker Act; district court retains or transfers incorrect | Consent decree/settlement is a contract; CFC has jurisdiction; case remanded to transfer. |
Key Cases Cited
- Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375 (1994) (retains jurisdiction to enforce if incorporated in dismissal order or retains jurisdiction clause)
- VanDesande v. United States, 673 F.3d 1342 (Fed. Cir. 2012) (settlement as contract under Tucker Act; enforcement in CFC possible)
- Shaffer v. Veneman, 325 F.3d 370 (D.C. Cir. 2003) (ancillary jurisdiction not guaranteed; insufficient for this ruling)
- Rufo v. Inmates of Suffolk County Jail, 502 U.S. 367 (1992) (limits on consent decrees; modification context)
- United States v. ITT Cont’l Banking Co., 420 U.S. 223 (1975) (consent decrees have contract-like attributes; not mutually exclusive with judgments)