George Andrew Benavides filed a complaint in the United States Court of Federal Claims seeking $65 million in damages. His suit alleged a variety of grievances against the United States, including a Fifth Amendment taking of his liberty, bodily integrity, and mental autonomy; breach of an implied contract arising from his enlistment in the U.S. Marine Corps; false imprisonment; retaliation; interference with his intellectual property rights; and loss of livelihood. The Court of Federal Claims dismissed the complaint, ruling that it lacked jurisdiction over the tort-based claims and that Benavides failed to state a plausible claim for relief regarding the takings and contract theories. Benavides appealed to the Federal Circuit, opposing the summary affirmance of the dismissal.
The Federal Circuit, issuing a Per Curiam order, analyzed whether the Court of Federal Claims had jurisdiction over Benavides's claims under the Tucker Act. The court first addressed the tort-based claims, including false imprisonment, retaliation, and interference with intellectual property rights. Citing precedent, the court reaffirmed that the Tucker Act does not grant jurisdiction over claims that sound in tort. The court noted that retaliation claims and interference with prospective business relations are traditionally torts, and false imprisonment is explicitly a tort. Consequently, the Court of Federal Claims correctly lacked jurisdiction over these allegations. Next, the court examined the contract claim. Benavides alleged a breach of an implied contract based on his enlistment. The court clarified that this amounted to a contract implied-in-law, which is outside the limited jurisdiction of the Court of Federal Claims, which is generally restricted to express contracts. Finally, the court addressed the Fifth Amendment takings claim. Benavides argued that the deprivation of his liberty, bodily integrity, and mental autonomy constituted a taking of property without just compensation. The court held that these concepts do not constitute property interests covered by the Takings Clause. Regarding the copyright infringement claim under 28 U.S.C. § 1498(b), the court found that Benavides failed to plausibly allege any cognizable act of infringement or a taking that would establish relief. Because the United States' position was clearly correct as a matter of law, the court determined that no substantial question regarding the outcome existed and granted the motion for summary affirmance.
The judgment of the Court of Federal Claims is summarily affirmed, meaning Benavides's $65 million suit is dismissed without relief. The decision reinforces the strict jurisdictional boundaries of the Court of Federal Claims, confirming that it cannot hear tort claims or claims based on implied-in-law contracts. It also clarifies that personal liberties and bodily integrity are not compensable property interests under the Takings Clause. There are no remand instructions as the case is dismissed; the plaintiff bears no costs, and each party bears its own costs.
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