Background
Dr. Camille Kamga sued the United States in the Court of Federal Claims, alleging that the Department of Transportation breached a grant agreement by terminating it on May 2, 2025. Kamga, director of a regional University Transportation Center known as SEMPACT, seeks money damages, interest, fees, costs, and expenses.
Eleven days later, Kamga filed a separate action in the Southern District of New York arising from the same termination. That case asserts constitutional and Administrative Procedure Act claims and seeks declaratory, vacatur, and injunctive relief. The parties jointly asked the Court of Federal Claims to stay the contract case until the district-court action concluded, citing judicial economy, the risk of conflicting orders, and the absence of prejudice.
The Court’s Holding
The court denied the joint motion to stay without prejudice. Applying the framework of Landis v. North American Co., it concluded that the parties had not demonstrated a pressing need for an indefinite stay. Their central premise—that relief in the district court could eliminate the need to decide the Court of Federal Claims action—was doubtful under the Supreme Court’s decisions in Department of Education v. California and National Institutes of Health v. American Public Health Association.
The court reasoned that an order reinstating the grant and releasing withheld funds would function as an order enforcing a contractual obligation to pay money, notwithstanding its characterization as equitable relief. Such a contract claim belongs in the Court of Federal Claims under the Tucker Act. Although prospective relief against DOT policies might have value independent of payment and potentially belong in district court, vacating those policies would not resolve whether Kamga is entitled to damages for breach of the grant agreement.
The court did not decide the district court’s jurisdiction or hold that a stay could never be warranted. It found only that the existing motion failed to show that deferring to the later-filed district-court case would resolve the claims before it more efficiently, particularly because the parties had not addressed 28 U.S.C. § 1500 or the significance of filing the Court of Federal Claims action first. The court granted the government’s alternative request for additional time and ordered it to respond to the complaint by October 16, 2026.
Key Takeaways
- Agreement between the parties and lack of prejudice do not, by themselves, justify an indefinite stay; the movants must first establish a pressing need.
- A request framed as vacatur or an injunction may still be a Tucker Act contract claim when its practical purpose is to compel the government to pay money under a grant agreement.
- Parallel equitable and monetary actions may proceed on separate tracks when the equitable relief has independent value, but the parties must explain how the other action could actually resolve the claims sought to be stayed.
Why It Matters
The order underscores the jurisdictional consequences of pursuing federal grant disputes after the Supreme Court’s decisions in California and NIH. Plaintiffs cannot necessarily move a payment dispute into district court merely by describing the requested remedy as vacatur, reinstatement, or injunctive relief.
For litigants pursuing parallel APA and Tucker Act cases, the decision also highlights the need to address the precise relationship between the requested remedies, the filing sequence, and § 1500. A renewed stay motion must explain which claims the district court can actually resolve and why that resolution would materially affect the first-filed damages action.