Scranage, Jr. v. United States, 17-1103

Plaintiff Clarence Scranage, Jr., a Virginia-licensed physician, was indicted (Feb 2017), placed on house arrest with an ankle monitor, tried, and convicted by a federal jury (Aug 10, 2017) for conspiracy to possess with intent to distribute oxycodone; sentencing was scheduled for Nov 17, 2017.
Scranage filed a pro se complaint in the Court of Federal Claims (Aug 14, 2017) challenging his arrest, conviction, and anticipated incarceration and alleging mental, emotional, and financial injury and deprivation of rights under 18 U.S.C. §§ 241 and 242.
The complaint sought judicial review and relief for those alleged injuries, but did not identify a money‑mandating statute or contract with the United States cognizable in the Court of Federal Claims under the Tucker Act.
The Court applied the more lenient pleading standard for pro se litigants but noted that leniency does not relieve a plaintiff of the burden to establish jurisdiction.
The Court found the claims to be criminal in nature, tort-based, or criminal‑code allegations—areas outside the Court of Federal Claims’ limited Tucker Act jurisdiction—and therefore dismissed for lack of subject‑matter jurisdiction.
The Court also declined to transfer the action to a district court under 28 U.S.C. § 1631 because the claims were frivolous or futile and not appropriate for a merits determination elsewhere.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Court of Federal Claims has jurisdiction to review criminal conviction/sentence	Scranage sought review of his arrest, conviction, and expected incarceration	Government argued the CFC lacks jurisdiction over criminal matters and habeas/criminal review	Dismissed: CFC lacks jurisdiction to review criminal convictions or sentences
Whether criminal‑code claims (18 U.S.C. §§ 241, 242) can be heard in CFC	Scranage alleged deprivation of rights under color of law	Government: federal criminal statutes are not a basis for CFC jurisdiction	Dismissed: CFC has no jurisdiction over criminal code claims
Whether tort‑based damages (emotional, financial) fall under Tucker Act	Scranage claimed mental/emotional and financial harm from house arrest/conviction	Government: tort claims ‘‘sound in tort’’ and are excluded from Tucker Act jurisdiction	Dismissed: tort claims not cognizable in CFC
Whether case should be transferred to a district court under 28 U.S.C. § 1631	Scranage implicitly sought relief reviewable in district court	Government: transfer not appropriate given merits are frivolous/futile	Denied transfer: not in interest of justice; transfer would be futile

Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375 (1994) (federal courts are courts of limited jurisdiction and may exercise only that power authorized by Constitution and statute)
Testan v. United States, 424 U.S. 392 (1976) (Tucker Act confers jurisdiction but does not create substantive rights for money damages)
United States v. Mitchell, 463 U.S. 206 (1983) (statutes or regulations must be money‑mandating to support Tucker Act jurisdiction)
Haines v. Kerner, 404 U.S. 519 (1972) (pro se pleadings are held to less stringent standards)
Hagans v. Lavine, 415 U.S. 528 (1974) (courts must dismiss claims that are "absolutely devoid of merit" for lack of jurisdiction)
Fisher v. United States, 402 F.3d 1167 (Fed. Cir. 2005) (interpretation of money‑mandating statutes for Tucker Act jurisdiction)
Arbaugh v. Y & H Corp., 546 U.S. 500 (2006) (subject‑matter jurisdiction cannot be forfeited or waived)
Trafny v. United States, 503 F.3d 1339 (Fed. Cir. 2007) (CFC lacks jurisdiction over tort claims)