Slaughter v. United States
133 Fed. Cl. 712
| Fed. Cl. | 2017Background
- Eddie Slaughter, an African-American Georgia farmer, participated in the Pigford class action challenging USDA discrimination in farm-loan programs; Pigford resulted in a 1999 consent decree creating procedures (Track A) for adjudicating individual claims for debt relief.
- An adjudicator in 2001 found discrimination as to Slaughter’s farm ownership loans and ordered discharge of those debts; adjudicators did not find discrimination for his operating and emergency loans.
- USDA sent Slaughter IRS Form 1099-C(s) reporting cancellation of debt (some forms mistakenly indicated cancellation of additional loans), and later communications were confusing or inconsistent about which loans were discharged.
- Slaughter sought reexamination in 2005; the 2005 adjudicator reaffirmed discharge for ownership loans only and denied relief for operating/emergency loans; Slaughter sued in the Middle District of Georgia in 2012, which dismissed for lack of jurisdiction.
- Slaughter sued the United States in the Court of Federal Claims in 2015 for breach of a “settlement agreement” or consent decree, alleging the 1099-C forms and other documents created contractual entitlement to discharge of all four loans.
- The Government moved to dismiss under RCFC 12(b)(1) and 12(b)(6), arguing (1) the consent decree is not a contract that creates Tucker Act jurisdiction, (2) the 1099-Cs were erroneous tax forms not contracts, and (3) the claim is time-barred or precluded by prior proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Court of Federal Claims has Tucker Act jurisdiction over Slaughter’s claim arising from the Pigford consent decree | Slaughter: consent decree is a contract/settlement creating substantive rights to debt discharge and thus Tucker Act jurisdiction | Gov: the consent decree is procedural (not a contract conferring money-mandating rights); jurisdiction lies with DC court/adjudicators | Held: No Tucker Act jurisdiction—the consent decree is procedural and does not create substantive money-mandating obligations |
| Whether USDA’s issuance of Form 1099-C (and related communications) created a bilateral contract obligating the Government to discharge additional loans | Slaughter: the 1099-C and USDA’s actions reasonably led him to believe debts were forgiven, constituting acceptance/consideration | Gov: 1099-Cs were erroneous tax reporting forms, not agreements or unilateral government contracts | Held: 1099-Cs do not create a contract; plaintiff failed to plead a plausible contract claim |
| Whether Slaughter’s claim is barred by the statute of limitations or revived by later government actions (e.g., returned garnishments) | Slaughter: repudiation and later actions (stop of garnishment/returns) delayed or revived accrual of breach | Gov: claim accrued earlier (2005 petition) and is time-barred | Held: Court did not accept plaintiff’s tolling/repudiation/revival theory and dismissed for lack of jurisdiction; also insufficient on the merits if jurisdiction existed |
| Whether adjudicators’ determinations preclude relitigation or require deference to district court supervision | Slaughter: Court of Federal Claims could hear breach regardless of district court procedures | Gov: adjudicators acted within consent decree authority; relief is governed by DC court process | Held: Court would not substitute its own findings for adjudicators; plaintiff cannot obtain relief inconsistent with adjudicators’ decisions |
Key Cases Cited
- Pigford v. Glickman, 185 F.R.D. 82 (D.D.C. 1999) (establishing consent decree and Track A adjudication process)
- Rick’s Mushroom Serv., Inc. v. United States, 521 F.3d 1338 (Fed. Cir. 2008) (Tucker Act jurisdiction requires a money-mandating substantive right)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (pleading standard for plausible entitlement to relief)
- VanDesande v. United States, 673 F.3d 1342 (Fed. Cir. 2012) (scope of Tucker Act and contract-based claims against the United States)
- Franklin-Mason v. Mabus, 742 F.3d 1051 (Fed. Cir. 2014) (Court of Federal Claims jurisdictional principles)
Conclusion: The Court of Federal Claims granted the Government’s motion and dismissed Slaughter’s complaint for lack of subject-matter jurisdiction under RCFC 12(b)(1) and for failure to state a claim under RCFC 12(b)(6).