Background
Marcus Deshawn Wright, proceeding pro se, sued the United States in the Court of Federal Claims seeking a tax refund. He alleged that the government failed to provide economic impact payments under the Coronavirus Aid, Relief, and Economic Security Act.
While that action was pending, Wright, an inmate at the U.S. Penitentiary in Tucson, Arizona, moved for a temporary restraining order. His motion alleged mistreatment at the prison, including interference with mail, denial of legal telephone access, denial of prison labor opportunities, and interference with his ability to exhaust administrative remedies.
The Court’s Holding
Judge Elaine D. Kaplan denied the motion for a temporary restraining order. The Court of Federal Claims generally lacks the broad authority to grant prospective equitable relief of the kind Wright sought, and none of the limited statutory circumstances authorizing equitable relief in that court applied.
The prison-condition allegations also concerned constitutional rights and torts, rather than money-mandating sources of law within the court’s Tucker Act jurisdiction. In addition, the requested injunction did not concern the alleged failure to provide economic impact payments—the subject of Wright’s complaint—so it did not seek to restrain conduct alleged in the underlying action to be unlawful.
Key Takeaways
- The Court of Federal Claims generally cannot issue prospective injunctive relief comparable to that available in federal district court.
- Claims concerning prison conditions, constitutional rights, and torts ordinarily fall outside the court’s jurisdiction absent a money-mandating source of law.
- A request for injunctive relief must relate to the conduct challenged in the operative complaint.
Why It Matters
The order underscores the jurisdictional limits on the Court of Federal Claims’ equitable powers. Litigants cannot use a pending monetary claim in that court to obtain emergency relief addressing unrelated prison-condition allegations.