Taylor v. United States
25-932
Fed. Cl.Jun 5, 2025Background
- Eric Emanuel Taylor, proceeding pro se, filed a complaint in the U.S. Court of Federal Claims on June 2, 2025, along with an application to proceed in forma pauperis (IFP).
- Taylor previously had a similar case dismissed as frivolous in U.S. District Court, and now challenges the Judge's dismissal as wrongful.
- Taylor alleges entitlement to a massive $347 billion award for a "false conviction" tort under the Federal Tort Claims Act and Civil Rights Act of 1866, tying his claim to Executive Order No. 14,173.
- Plaintiff makes unconventional arguments, including claims that the U.S. is both a plaintiff and a defendant, and that the U.S. is the "surety" of his relief.
- Plaintiff has a lengthy history of frivolous and vexatious litigation, resulting in prior pre-filing injunctions against him in other courts.
- The present court analyzed both whether Taylor's claims were frivolous and whether it had jurisdiction to hear the matter.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Frivolity of claims | Claims valid, seeks enormous damages for alleged wrongs | Claims are frivolous and irrational | Claims are frivolous, warranting dismissal |
| Failure to state a claim | Sufficient basis under Federal Tort Claims Act & Civil Rights Act | No factual allegations supporting relief | Complaint fails to state a plausible claim |
| Jurisdiction over collateral attack | Court should review prior District Court decision | Court cannot review Art. III court decisions | Court lacks jurisdiction to review District Court rulings |
| In forma pauperis status | Entitled due to inability to pay filing fees | Not warranted due to frivolous history | IFP denied due to frivolity and litigation abuse |
Key Cases Cited
- United States v. Mitchell, 463 U.S. 206 (Tucker Act does not create enforceable rights; requires independent source of law)
- Fisher v. United States, 402 F.3d 1167 (To invoke Tucker Act, must identify a source of law for money damages)
- Denton v. Hernandez, 504 U.S. 25 (Standards for dismissal as frivolous include fanciful, fantastic, or delusional allegations)
- Ashcroft v. Iqbal, 556 U.S. 662 (Pleading must plausibly state a claim to relief)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (Complaint must rise above speculative level)
- Joshua v. United States, 17 F.3d 378 (Court of Federal Claims cannot review decisions of other courts or collaterally attack them)