Background
Rodrick Maurice Brayboy, a Pennsylvania state prisoner proceeding pro se, sued after alleging that the Eastern District of Pennsylvania, the Third Circuit, and initially Pennsylvania correctional and parole entities violated his due-process and equal-protection rights in connection with habeas proceedings and his incarceration. He sought extraordinary monetary damages, declaratory relief, and relief tied to his alleged unlawful imprisonment.
Brayboy invoked the Tucker Act and initially 28 U.S.C. § 1495, the unjust-conviction statute. He later sought to remove the state defendants and replace his § 1495 theory with an asserted obstruction-of-justice claim. Because he had accumulated at least three prior qualifying dismissals, he also sought to proceed in forma pauperis by alleging imminent danger after an assault and an alleged conspiracy involving a federal court and prison officials.
The Court’s Holding
Chief Judge Matthew H. Solomson denied Brayboy’s in forma pauperis application, denied his second motion to amend as futile, granted the government’s motion to dismiss, and dismissed the complaint for lack of subject-matter jurisdiction. The court held that Brayboy did not satisfy the Prison Litigation Reform Act’s imminent-danger exception to the three-strikes rule because his assertions lacked a nexus to claims within the court’s jurisdiction and were conclusory and fantastical.
The court further held that the Tucker Act did not supply jurisdiction because the Due Process and Equal Protection Clauses are not money-mandating. Although § 1495 can support an unjust-imprisonment claim, Brayboy did not allege the required reversal, acquittal, or pardon based on innocence, and the Court of Federal Claims cannot independently review or overturn a criminal conviction. The court also lacked jurisdiction over claims against state entities and over challenges to federal district-court decisions.
Key Takeaways
- A three-strikes prisoner must show a concrete nexus between an imminent physical danger and a claim the court has authority to resolve.
- Due-process and equal-protection allegations do not independently establish Tucker Act jurisdiction because those constitutional provisions are not money-mandating.
- Section 1495 does not permit the Court of Federal Claims to revisit a conviction; its strict prerequisites include a qualifying reversal, acquittal, or pardon.
Why It Matters
The order underscores that the imminent-danger exception to the PLRA filing-fee bar does not cure a jurisdictional defect. A prisoner invoking the exception must plead a plausible, current danger tied to relief the court can actually provide.
It also reiterates the narrow role of the Court of Federal Claims: it cannot act as an appellate forum for federal criminal proceedings or district-court rulings, and it cannot adjudicate claims against state defendants.