Taylor v. United States, 666 F. App'x 896

Background

In 2006 a Virginia grand jury indicted Eric E. Taylor for malicious wounding (a class three felony); the state circuit court ultimately convicted him of unlawful wounding (a class six felony) and sentenced him to five years.
In 2016 Taylor sued in the Court of Federal Claims seeking monetary damages for alleged violations of the Fifth Amendment double jeopardy clause, a Fourteenth Amendment claim (invoking §4), a §1983 double jeopardy claim, and damages for unjust conviction and imprisonment; he sought an unspecified very large sum.
The Court of Federal Claims dismissed the complaint for lack of jurisdiction under the Tucker Act, reasoning that neither the Double Jeopardy Clause nor §4 of the Fourteenth Amendment is money‑mandating; it also dismissed tort‑style damages (pain and suffering) and held the court lacked jurisdiction over §1983 claims and state‑court criminal convictions.
The court further rejected Taylor’s attempt to proceed under 28 U.S.C. § 1495 (damages for unjust conviction of offenses against the United States) because his conviction was by a state court and he had not alleged or produced the statutory certificate/pardon required by 28 U.S.C. § 2513.
Taylor appealed, challenging the dismissal of his constitutional claims and the §1495 claim; the Federal Circuit affirmed, holding the Court of Federal Claims lacked jurisdiction over those claims.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Tucker Act jurisdiction for constitutional double jeopardy and §4 Fourteenth Amendment claims	Taylor argued his constitutional rights were violated and sought money damages from the United States.	The United States argued neither provision is money‑mandating and so the Tucker Act does not waive sovereign immunity for these claims.	Held: No jurisdiction — neither provision is money‑mandating; claims dismissed.
Jurisdiction under 28 U.S.C. § 1495 for unjust conviction and imprisonment	Taylor sought damages under §1495 for unjust conviction and imprisonment.	The United States argued §1495 applies only to convictions for offenses against the United States and requires statutory allegations and a court certificate or pardon under §2513.	Held: Dismissed — Taylor was convicted by a state court and failed to plead or prove the statutory requirements.
Ability of the Court of Federal Claims to hear §1983 claims	Taylor asserted a §1983 damages claim for double jeopardy violation.	The United States argued §1983 jurisdiction lies in federal district courts under 28 U.S.C. §1343, not the Court of Federal Claims.	Held: Dismissed for lack of jurisdiction (Taylor waived the issue on appeal but dismissal is correct).
Challenge to state‑court conviction via Court of Federal Claims	Taylor sought relief that would effectively challenge the validity of his state conviction.	The United States argued the Court of Federal Claims lacks jurisdiction to review state criminal convictions.	Held: Court of Federal Claims lacks jurisdiction to review state criminal convictions; such attacks are outside its scope.

Key Cases Cited

United States v. Mitchell, 463 U.S. 206 (the source of law must fairly be interpreted as mandating money damages)
Fisher v. United States, 402 F.3d 1167 (claim must identify a separate money‑mandating source to invoke Tucker Act)
Jones v. Caldera, 159 F.3d 573 (Double Jeopardy Clause is not money‑mandating)
Cochrun v. United States, [citation="621 F. App'x 655"] (Court of Federal Claims lacks jurisdiction to review state court convictions)
Jones v. United States, [citation="440 F. App'x 916"] (Court of Federal Claims has no jurisdiction over criminal matters generally)