Background
Incarcerated pro se plaintiff Christopher L. Stewart sued the United States in the Court of Federal Claims. His complaint and amended complaint alleged that Colorado and the U.S. District Court for the District of Colorado had engaged in “diversity fraud” connected to litigation he associated with cases in Colorado and the Middle District of Louisiana.
Stewart asked the court to reverse and remand the asserted wrongdoing, consolidate matters with the Louisiana case, and recover amounts allegedly not awarded. The government moved to dismiss for lack of subject-matter jurisdiction. The court allowed Stewart’s amended pleadings to be filed.
The Court’s Holding
Judge Thompson M. Dietz dismissed the action for lack of subject-matter jurisdiction. Even liberally construing the pro se pleadings, the court held that Stewart identified no money-mandating source of law supporting a claim against the United States under the Tucker Act.
The court also held that it lacks jurisdiction over claims against Colorado or other state actors and cannot review decisions made by, or matters pending in, federal district courts. Although the Court of Federal Claims may transfer a case when justice requires, it declined to transfer this one because Stewart’s allegations were too unclear to identify an appropriate transferee court, did not appear nonfrivolous, and concerned forums in which he had already litigated or attempted to litigate related matters.
Key Takeaways
- The Tucker Act does not itself create a cause of action; a plaintiff must identify a separate money-mandating source of law.
- The Court of Federal Claims cannot adjudicate claims against states or function as an appellate court for federal district-court proceedings.
- Transfer under 28 U.S.C. § 1631 is not warranted when the alleged wrongs are too unclear to identify a proper transferee forum.
Why It Matters
The order underscores the jurisdictional limits on the Court of Federal Claims, including for pro se pleadings. A liberal construction does not cure the absence of a claim for money damages against the United States grounded in a money-mandating source of law.
The court granted Stewart’s motions to amend, denied the government’s dismissal motion as moot, and dismissed the operative pleadings sua sponte under RCFC 12(h)(3).