Plaintiff Angeliina Lynn Lawson appealed a final judgment from the United States Court of Federal Claims that dismissed her case for lack of jurisdiction. Lawson's suit followed an unsuccessful attempt to remove a Kansas state-court custody proceeding to federal court. Her complaint sought $50,000,000 in damages based on alleged federal non-action by the United States Court of Appeals for the Tenth Circuit, claiming violations of access, due process, and ADA obligations. The Court of Federal Claims dismissed the case and certified that any appeal would not be taken in good faith, yet Lawson proceeded with her appeal to the Federal Circuit.
The Federal Circuit determined that summary affirmance was appropriate because no substantial question existed regarding the dismissal. The court reasoned that the Court of Federal Claims is a court of limited jurisdiction. Under the Tucker Act, 28 U.S.C. § 1491(a)(1), its jurisdiction extends only to money judgments in suits brought against the United States itself. Lawson's allegations of wrongdoing were directed at state and local actors in the custody proceeding and, more generally, at the Tenth Circuit for not granting her requested relief. The court cited United States v. Sherwood to confirm that the Tucker Act does not grant authority to adjudicate claims against state actors. Furthermore, the court noted that the Court of Federal Claims cannot entertain a claim that requires the court to scrutinize the actions of another tribunal. Because Lawson's claims fell outside the scope of suits against the United States and involved scrutiny of another tribunal's actions, the lower court correctly dismissed the case.
The judgment of the United States Court of Federal Claims is affirmed, meaning the dismissal of Lawson's case stands. All pending motions are denied, and each side must bear its own costs. The decision reinforces the strict jurisdictional limits of the Court of Federal Claims under the Tucker Act, preventing it from serving as a venue for claims against state actors or for reviewing the actions of other federal tribunals.
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