Spengler v. United States
688 F. App'x 917
Fed. Cir.2017Background
- Andrew Spengler, a federal inmate, sued the United States in the Court of Federal Claims alleging the Bureau of Prisons (BOP) breached fiduciary duties by misusing the prison Commissary Fund and sought damages and injunctive relief.
- Spengler relied on 31 U.S.C. § 1321 (which classifies commissary funds as “trust funds”) and DOJ Circular 2244 to argue the government assumed a fiduciary duty exposing it to Tucker Act money-claims.
- He alleged commissary monies were diverted to inmate computer/telephone systems and related items and sought accounting, restoration of funds, destruction of collected personal data, and damages.
- The Government moved to dismiss for lack of Tucker Act jurisdiction, arguing the statutory/regulatory materials did not impose money-mandating fiduciary duties.
- The Court of Federal Claims dismissed without prejudice for lack of subject-matter jurisdiction and declined to transfer to a district court, finding Spengler had not exhausted administrative remedies under the PLRA.
- The CFC then denied Spengler’s post-judgment RCFC 59/60 motion as untimely and not entitling him to relief; the Federal Circuit affirmed on jurisdiction, transfer, and post-judgment issues.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Court of Federal Claims has Tucker Act jurisdiction for Spengler’s suit alleging breach of fiduciary duty over commissary funds | §1321 and DOJ Circular 2244 classify commissary monies as a statutory trust and thus impose fiduciary duties that are money-mandating | The statutory designation and circular create at most a "bare" or limited trust; they do not impose specific fiduciary obligations that mandate money damages under the Tucker Act | No jurisdiction: designation as a trust alone is insufficient; plaintiff failed to identify statutes/regulations that impose specific, money-mandating fiduciary duties |
| Whether the case should be transferred to a district court under 28 U.S.C. § 1631 | Transfer appropriate because claims implicate prison conditions and Spengler had (or was obstructed from) exhausting administrative remedies | Spengler failed to exhaust PLRA administrative remedies; the claim is not framed under any separate district-court cognizable waiver of sovereign immunity | No transfer: Spengler did not complete administrative exhaustion and did not plead a separate district-court cause of action or waiver |
| Whether Spengler was excused from exhaustion due to BOP obstruction | Grievance delays and obstructions prevented exhaustion, excusing the requirement | Record shows grievances were initiated but not completed; no proof BOP prevented completion | Not excused: plaintiff failed to show he was prevented from completing grievance process |
| Whether the CFC abused its discretion by denying Spengler’s RCFC 59/60 post-judgment motion | Motion timely under the prison mailbox rule; newly completed grievances and a prior settlement in Washington v. Reno constitute new evidence warranting relief | Motion untimely; prison-mailbox rule does not change the deadline; submitted grievances were not newly discoverable and would not change result | No abuse of discretion: motion untimely and the new materials would not alter jurisdictional conclusion |
Key Cases Cited
- United States v. White Mountain Apache Tribe, 537 U.S. 465 (establishes Tucker Act waiver framing and need for money-mandating source)
- United States v. Testan, 424 U.S. 392 (Tucker Act is jurisdictional only; does not create substantive rights)
- United States v. Mitchell, 463 U.S. 206 (Mitchell II) (substantive source required for money-mandating fiduciary claims)
- United States v. Navajo Nation, 537 U.S. 488 (requires specific statutory/regulatory prescriptions to impose fiduciary duties)
- United States v. Navajo Nation, 556 U.S. 287 (Navajo II) (trust-evoking, duty-imposing text required before applying trust principles to award damages)
- Hopi Tribe v. United States, 782 F.3d 662 (Fed. Cir.) (identifies hallmarks of conventional fiduciary relationship for Tucker Act purposes)
- Porter v. Nussle, 534 U.S. 516 (prisoner PLRA exhaustion requirements)
- Washington v. Reno, 35 F.3d 1093 (6th Cir.) (distinct context — sought injunctive relief; not binding on Federal Circuit and did not address Tucker Act jurisdiction)