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Zeigler v. United States
19-889
| Fed. Cl. | Oct 22, 2019
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Background

  • Plaintiff Stephanie Jones‑Zeigler, proceeding pro se, sued alleging ADA violations by unnamed prospective employers and that a state vocational rehabilitation counselor failed to assist her in obtaining employment.
  • She sought unspecified backpay, costs, and damages for pain and suffering.
  • The case was filed in the United States Court of Federal Claims; the government moved to dismiss under RCFC 12(b)(1) and 12(b)(6).
  • Jones‑Zeigler did not respond to the motion; she filed a motion to proceed in forma pauperis, which the Court granted.
  • The Court concluded it lacked jurisdiction because claims against non‑United States parties are outside Tucker Act jurisdiction, and the ADA is not a money‑mandating statute that confers jurisdiction in the Court of Federal Claims (the ADA does not impose liability on the United States as an employer).
  • The government’s motion to dismiss for lack of subject‑matter jurisdiction was granted and the complaint was dismissed without prejudice; each side to bear its own costs.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether CFC has jurisdiction over claims asserted against non‑federal parties Jones‑Zeigler sought relief against prospective employers and a state counselor The CFC’s Tucker Act jurisdiction extends only to money judgments against the United States; claims against others are outside the Court’s jurisdiction Dismissed: claims against non‑United States parties are beyond CFC jurisdiction
Whether the ADA provides a money‑mandating source that confers CFC jurisdiction Jones‑Zeigler invoked the ADA to obtain backpay and damages The ADA is not a statute mandating payment by the United States and does not make the U.S. liable as an employer for CFC jurisdiction; ADA claims are for district courts Dismissed: ADA does not provide a money‑mandating waiver; CFC lacks jurisdiction

Key Cases Cited

  • Jan's Helicopter Serv., Inc. v. Fed. Aviation Admin., 525 F.3d 1299 (Fed. Cir. 2008) (Tucker Act requires a separate money‑mandating source for CFC jurisdiction)
  • Fisher v. United States, 402 F.3d 1167 (Fed. Cir. 2005) (the Tucker Act does not itself create a substantive cause of action)
  • Haines v. Kerner, 404 U.S. 519 (1972) (pro se pleadings are held to less stringent standards)
  • United States v. Sherwood, 312 U.S. 584 (1941) (CFC jurisdiction is confined to money judgments against the United States; claims against others must be ignored)
  • Searles v. United States, 88 Fed. Cl. 801 (2009) (ADA is not money‑mandating; ADA claims against the federal government generally do not give rise to CFC jurisdiction)
  • Boddie v. United States, 86 F.3d 1178 (Fed. Cir. 1996) (ADA does not apply to the federal government as an employer)
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Case Details

Case Name: Zeigler v. United States
Court Name: United States Court of Federal Claims
Date Published: Oct 22, 2019
Docket Number: 19-889
Court Abbreviation: Fed. Cl.