Staff Sergeant Justin Paul Dreiling filed a pro se complaint in the United States Court of Federal Claims alleging that the United States Army Installation Management Command exceeded its authority by requiring children to receive the annual influenza vaccine to participate in youth soccer leagues on Fort Leonard Wood. Dreiling claimed this regulation violated his constitutionally protected parental rights and sought injunctive relief to have the regulation deemed unenforceable. The government moved to dismiss, arguing the Court of Federal Claims lacked jurisdiction. The lower court dismissed the case, concluding that Dreiling failed to identify a money-mandating source of law under the Tucker Act and that transferring the case to a district court would be futile because his claims failed to state a valid cause of action.
The Federal Circuit reviewed the jurisdictional question de novo. The court explained that the Tucker Act grants the Court of Federal Claims jurisdiction over claims against the United States founded upon the Constitution, statutes, or regulations, but only for 'liquidated or unliquidated damages in cases not sounding in tort.' Under established precedent, a plaintiff must identify a money-mandating source of law that 'can fairly be interpreted as mandating compensation by the Federal Government for the damage sustained.' Dreiling argued that the plain language of the Tucker Act allows for equitable claims and that the court should overrule binding Supreme Court precedent to conform with his interpretation. The court rejected this, stating it has no power to overturn long-standing precedent holding that the Court of Federal Claims' jurisdiction is limited to monetary claims. Since Dreiling sought injunctive relief rather than monetary damages and failed to identify a money-mandating source of law, the Court of Federal Claims correctly lacked subject matter jurisdiction.
The dismissal for lack of subject matter jurisdiction stands, meaning Dreiling receives no judicial relief on the merits of his vaccination policy challenge. The decision reinforces the strict limitation that the Court of Federal Claims cannot hear equitable claims unless a statute or regulation explicitly mandates compensation. Plaintiffs challenging government regulations for injunctive relief must file in district court rather than the Court of Federal Claims, unless they can frame the claim as one for monetary damages supported by a money-mandating source of law.
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