Natasha Collins, represented by All Star Entertainment, filed a lawsuit in the United States District Court for the Eastern District of Pennsylvania seeking to compel the Small Business Administration to grant her application for economic aid under the Shuttered Venue Operators Grant program. The District Court dismissed the suit. Collins then filed a notice of appeal directed to the Federal Circuit. The SBA responded by urging dismissal, while Collins requested relief on the merits. The Federal Circuit was called upon to determine whether it had the statutory authority to hear this specific type of administrative dispute.
The Federal Circuit's jurisdiction is strictly limited by statute. Under 28 U.S.C. § 1295, the court generally reviews cases involving patent laws, appeals from the United States Patent and Trademark Office, or certain damages claims against the United States not exceeding $10,000. This case involves a claim for economic aid from the SBA, which does not fall within the patent laws, is not a claim from the PTO, and is not a small tort damages claim. Because the dispute concerns a non-patent, non-tort claim against the SBA, it falls outside the specific statutory grants of jurisdiction for the Federal Circuit. The court noted that while it lacks jurisdiction, it has the power to transfer cases to the proper court.
The appeal is transferred to the United States Court of Appeals for the Third Circuit pursuant to 28 U.S.C. § 1631. This transfer allows the case to proceed in a court with the correct subject matter jurisdiction, avoiding the delay and expense of a dismissal and re-filing. The underlying dispute regarding the Shuttered Venue Operators Grant will now be adjudicated by the Third Circuit.
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