Watkins v. United States
128 Fed. Cl. 593
| Fed. Cl. | 2016Background
- Plaintiff Theodore Watkins (pro se) pled guilty in Michigan state court in 1976 and 1980 and was later sentenced in 1982 after a probation violation; one sentence was vacated on jurisdictional grounds but his guilty plea remained.
- Watkins filed a prior suit in the Court of Federal Claims (Watkins I, 2015) asserting that as a member of a purported sovereign nation he was immune under FSIA and that the government failed to follow procedures to "remove [his] immunity;" that suit was dismissed for lack of jurisdiction and for failure to state a money-mandating claim.
- On January 19, 2016 Watkins filed an essentially identical Complaint (Watkins II) in the Court of Federal Claims seeking settlement/closure and challenging procedural defects surrounding his state-court plea and alleged removal of immunity.
- The government moved to dismiss Watkins II under RCFC 12(b)(1) and 12(b)(6) for lack of subject-matter jurisdiction and on res judicata / collateral estoppel grounds; Watkins did not respond and did not cure jurisdictional defects.
- The court analyzed Tucker Act jurisdiction and the Tucker Act’s requirement that a plaintiff identify a money-mandating source of law, and reviewed doctrines of claim preclusion and issue preclusion as to the prior dismissal.
- The court granted the government’s motion and dismissed Watkins II for lack of jurisdiction and failure to state a claim, holding that many defendants and claims were outside the Claims Court’s jurisdiction and that res judicata did not apply to the prior jurisdictional dismissal; collateral estoppel barred re‑litigation of some jurisdictional issues that Watkins had had the opportunity to litigate.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Court’s subject-matter jurisdiction under Tucker Act | Watkins contends the US failed to follow procedures removing his sovereign immunity and seeks relief in Claims Court | Gov't: Claims Court lacks jurisdiction over state actors and lacks money‑mandating source; prior dismissal shows no jurisdiction | Dismissed: Watkins fails to identify a money‑mandating source; Claims Court lacks jurisdiction over state/individual defendants and the substantive claims alleged |
| Effect of prior dismissal (res judicata) | Watkins refiled essentially same claims, implying claim should proceed | Gov't: Prior dismissal bars relitigation under res judicata | Denied: Res judicata inapplicable because prior dismissal was, in part, for lack of jurisdiction (not a merits adjudication) |
| Effect of prior dismissal (collateral estoppel) | Watkins attempts to litigate same jurisdictional/substantive issues | Gov't: Issue preclusion bars relitigation of issues actually litigated and necessarily decided | Partially sustained: Collateral estoppel can bar relitigation of jurisdictional determinations that were actually litigated and essential, and a plaintiff who had full opportunity cannot reopen them; but jurisdictional dismissals do not always have preclusive effect if defects could be cured |
| Failure to state a money‑mandating claim | Watkins alleges violations of FSIA and regulations to justify relief | Gov't: Statutes/regulations invoked are not money‑mandating and do not create Tucker Act relief | Dismissed: Plaintiff did not plead a separate money‑mandating source of law; dismissal under RCFC 12(b)(6) appropriate when an affirmative defense (like issue preclusion) bars relief |
Key Cases Cited
- United States v. Testan, 424 U.S. 392 (Tucker Act confers jurisdiction but does not itself create substantive money‑mandating rights)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (pleading standard: must state plausible claim)
- Ashcroft v. Iqbal, 556 U.S. 662 (pleading standards and reasonable inferences)
- Haines v. Kerner, 404 U.S. 519 (pro se complaints construed liberally)
- Allen v. McCurry, 449 U.S. 90 (res judicata bars relitigation of claims decided on the merits)
- Ins. Corp. of Ireland v. Compagnie des Bauxites de Guinee, 456 U.S. 694 (preclusive effect of jurisdictional determinations)
- Shell Petroleum, Inc. v. United States, 319 F.3d 1334 (elements for issue preclusion in Federal Circuit)
- Faust v. United States, 101 F.3d 675 (res judicata principles in Federal Circuit)