Townsend v. United States, 16-1424

Plaintiff William A. Townsend, a Florida state prisoner convicted of first-degree murder (life without parole), sued the United States in the Court of Federal Claims challenging his conviction and conditions of incarceration.
Complaint alleged interference with his mail, First Amendment violations, and that he is being detained against his will; cited 28 U.S.C. § 2254 and 42 U.S.C. § 1983 as bases.
Townsend previously filed materially similar suits and habeas petitions in multiple federal district courts and one prior action in this Court that were dismissed.
The government moved to dismiss for lack of subject-matter jurisdiction under RCFC 12(b)(1); the Court raised jurisdiction sua sponte under RCFC 12(h)(3).
The Court concluded it lacks jurisdiction to review criminal convictions, to hear § 1983 civil-rights claims, and to entertain tort claims against the United States, and dismissed the complaint without transfer.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Court of Federal Claims has jurisdiction over challenges to a state criminal conviction and incarceration conditions	Townsend contends his custody and prison conditions violate federal law and cites § 2254 and § 1983	Government argued the Court lacks subject-matter jurisdiction over criminal matters and civil-rights claims	Court held it lacks jurisdiction and dismissed under RCFC 12(h)(3)
Whether § 1983 claims may be brought in Court of Federal Claims	Townsend invoked § 1983 for constitutional violations by prison officials	Government maintained § 1983 is not within this Court's jurisdictional grant	Court held it may not entertain § 1983 claims and dismissed
Whether transfer to a district court is appropriate under 28 U.S.C. § 1631	Townsend did not expressly seek transfer; sought relief in federal fora	Government did not advocate transfer; argued dismissal appropriate	Court declined transfer as futile given prior dismissals and not in interest of justice
Whether pro se status alters jurisdictional requirement	Townsend pro se argued leniency should apply to his pleadings	Government noted pro se status does not eliminate jurisdictional limits	Court applied liberal pleading standards but maintained plaintiff bears burden to establish jurisdiction; dismissal affirmed

Plains Comm. Bank v. Long Family Land & Cattle Co., 554 U.S. 316 (subject-matter jurisdiction must be established before addressing merits)
Steel Co. v. Citizens for a Better Env't, 523 U.S. 83 (jurisdiction is a threshold question)
Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375 (federal courts of limited jurisdiction must identify statutory authorization)
United States v. Testan, 424 U.S. 392 (Tucker Act confers jurisdiction but does not create substantive money-mandating rights)
United States v. Mitchell, 463 U.S. 206 (statute/regulation is money-mandating if fairly interpreted to mandate compensation)
Haines v. Kerner, 404 U.S. 519 (pro se pleadings are held to less stringent standards)
Arbaugh v. Y & H Corp., 546 U.S. 500 (subject-matter jurisdiction cannot be forfeited or waived)
Henderson ex rel. Henderson v. Shinseki, 562 U.S. 428 (courts have independent obligation to ensure they do not exceed jurisdiction)