Also known as: U.S. Court of Federal Claims · Court of Federal Claims · US Court of Federal Claims · COFC · Fed. Cl.
Written by attorneys — see sources below.
A specialized federal court established under Article I of the Constitution with original nationwide jurisdiction to render money judgments on claims against the United States founded on the Constitution, a federal statute, a federal regulation, an express or implied-in-fact contract, or other claims for damages not sounding in tort.
Una Unger filed a civil action in the United States Court of Federal Claims seeking damages after a federal agency denied her company's banking license. At trial the agency attempted to introduce transcripts from an earlier administrative hearing conducted without formal evidentiary constraints. The court applied the Federal Rules of Evidence to determine admissibility of the transcripts.
Ulysses Ulrich sued the United States in federal district court alleging that a federal statute effected an unconstitutional taking of his coal-mining interests. The government moved to dismiss for lack of jurisdiction because the claim sought more than ten thousand dollars in compensation. The district court transferred the action to the United States Court of Federal Claims under the Tucker Act.
Eastern Enterprises was organized as a Massachusetts business trust in 1929 under the name Eastern Gas and Fuel Associates. Until 1965, Eastern conducted extensive coal mining operations centered in West Virginia and Pennsylvania. As a signatory to each National Bituminous Coal Wage Agreement executed between 1947 and 1964, Eastern made contributions of over $60 million to the 1947 and 1950 Welfare and Retirement Funds. In 1963, Eastern decided to transfer its coal-related operations to a subsidiary, Eastern Associated Coal Corp. The transfer was completed by the end of 1965. It was described in Eastern's federal income tax return as an agreement by EACC to assume all of Eastern's liabilities arising out of coal mining and marketing operations in exchange for Eastern's receipt of EACC's stock. Eastern retained its stock interest in EACC through a subsidiary corporation, Coal Properties Corp., until 1987. It received dividends of more than $100 million from EACC during that period. In 1987, Eastern sold its interest in Coal Properties Corp. to Peabody Holding Company, Inc. Following enactment of the Coal Industry Retiree Health Benefit Act of 1992, the Commissioner of Social Security assigned to Eastern the obligation for Combined Fund premiums respecting over 1,000 retired miners who had worked for the company before 1966. The assignment rested on Eastern's status as the pre-1978 signatory operator for whom the miners had worked for the longest period of time. Eastern's premium for a 12-month period exceeded $5 million. Eastern responded by suing the Commissioner, as well as the Combined Fund and its trustees, in the United States District Court for the District of Massachusetts. Eastern asserted that the Coal Act, either on its face or as applied, violates substantive due process and constitutes a taking of its property in violation of the Fifth Amendment. The District Court granted summary judgment for respondents on all claims. The Court of Appeals for the First Circuit affirmed. The Supreme Court granted certiorari.
Usman Uddin acquired land subject to an old railroad right-of-way that the United States later claimed had reverted to federal ownership. He filed suit in the United States Court of Federal Claims seeking just compensation for an alleged taking. The court examined whether the original grant created an easement or a fee simple determinable.
In 1908 the Laramie, Hahn's Peak and Pacific Railroad obtained a 200-foot-wide right of way across public lands in Wyoming under the General Railroad Right-of-Way Act of 1875. The railroad completed construction of its line in 1911. The line later passed through several owners and was used primarily to transport timber and cattle. In 1976 the United States issued a land patent conveying an 83-acre parcel in Fox Park, Wyoming, to Melvin and Lulu Brandt. The patent conveyed to the Brandts fee simple title to the land "with all the rights, privileges, immunities, and appurtenances, of whatsoever nature, thereunto belonging, unto said claimants, their successors and assigns, forever." The patent stated that the land was granted "subject to those rights for railroad purposes as have been granted to the Laramie[,] Hahn's Peak & Pacific Railway Company, its successors or assigns." The right of way crossed approximately ten acres of the patented parcel. In 1996 the Wyoming and Colorado Railroad notified the Surface Transportation Board of its intent to abandon the right of way. After removing the tracks and ties and obtaining Board approval, the railroad completed abandonment in 2004. In 2006 the United States filed suit seeking a judicial declaration of abandonment and an order quieting title to the right of way in the Government. The complaint named the owners of 31 parcels crossed by the abandoned right of way, including Marvin Brandt who held the Fox Park parcel through a family trust. Brandt contested the claim and filed a counterclaim asserting that the right of way was a mere easement extinguished by abandonment. The district court granted summary judgment to the United States. The Court of Appeals for the Tenth Circuit affirmed. The Supreme Court granted certiorari.
Ursula Ureña managed timberland that suffered repeated seasonal flooding after the Army Corps of Engineers altered upstream water releases. She brought an action in the United States Court of Federal Claims asserting that the cumulative flooding constituted a temporary taking. The court assessed whether the invasions were sufficiently substantial to require compensation.
The Arkansas Game and Fish Commission owns and manages the Dave Donaldson Black River Wildlife Management Area. This area consists of 23,000 acres of forested land along both banks of the Black River in northeast Arkansas. The Area supports hardwood timber species, primarily nuttall, overcup, and willow oaks. It serves as a wildlife habitat and hunting preserve where the Commission conducts regular timber harvests. In 1948 the U.S. Army Corps of Engineers constructed the Clearwater Dam 115 miles upstream from the Management Area. The Corps adopted a Water Control Manual that prescribed seasonally varying rates for water releases from the Dam while allowing for planned deviations to accommodate agricultural, recreational, and other purposes. From 1993 through 2000 the Corps authorized annual deviations from the Manual in response to requests from downstream farmers. These deviations involved slower water releases during the fall months. The slower releases caused water to accumulate behind the Dam and necessitated extended high-volume releases that produced flooding on the Management Area during the April-to-October growing season at levels substantially above historical averages. The Commission lodged repeated objections to the deviations during this period. In 2005 the Commission commenced an action against the United States in the Court of Federal Claims. The Commission asserted that the cumulative impact of the flooding from 1993 to 1999 had destroyed more than 18 million board feet of timber and required costly reclamation. Following a trial the Court of Federal Claims issued detailed findings of fact and awarded the Commission $5.7 million. The Federal Circuit reversed that judgment. The Supreme Court granted certiorari.
Uri Underwood refused to surrender a portion of his raisin crop to the government under a marketing order and faced penalties. He filed suit in the United States Court of Federal Claims alleging that the required surrender effected a physical taking of his property. The court evaluated whether the mandate constituted a per se taking under the Fifth Amendment.
The Agricultural Marketing Agreement Act of 1937 authorizes the Secretary of Agriculture to promulgate marketing orders to help maintain stable markets for particular agricultural products. Under the resulting California Raisin Marketing Order, growers must give a percentage of their crop to the Government free of charge in years when the Committee sets a reserve requirement. The Raisin Administrative Committee determined the allocation at 47 percent in 2002-2003 and 30 percent in 2003-2004. Growers generally ship their raisins to a handler. The handler physically separates the reserve raisins due the Government, pays the growers only for the free-tonnage raisins, and packs and sells the free-tonnage raisins. The Raisin Committee acquires title to the reserve raisins that have been set aside and decides how to dispose of them in its discretion. Proceeds from Committee sales are principally used to subsidize handlers who sell raisins for export. Raisin growers retain an interest in any net proceeds after deductions for export subsidies and the Committee's expenses. The Hornes are both raisin growers and handlers. They handled their own raisins and raisins produced by other growers, paying those growers in full for all of their raisins, not just the free-tonnage portion. In 2002 the Hornes refused to set aside any raisins for the Government. The Government assessed a fine equal to the market value of the missing raisins—about $480,000—and an additional civil penalty of just over $200,000 for disobeying the order. When the Government sought to collect the fine, the Hornes sued, arguing that the reserve requirement was an unconstitutional taking under the Fifth Amendment. This Court previously held that the Hornes could present their constitutional defense and remanded for consideration on the merits. On remand, the Ninth Circuit viewed the reserve requirement as a use restriction rather than a per se taking. The Supreme Court granted certiorari.
The United States Court of Federal Claims possesses that exclusive jurisdiction under the Tucker Act. District courts lack authority to entertain such claims when the amount in controversy exceeds the statutory threshold. Transfer to the Court of Federal Claims is therefore required when the claim falls within its specialized monetary jurisdiction.
…answer to Eastern's complaint: Whether petitioner's takings claim was properly filed in Federal District Court rather than the United States Court of Federal Claims. See App. (CA1) 40. Although the Commissioner no longer challenges the Court's adjudication of this action, see Brief for Federal Respondent 38-39, n. 30, it is appropriate that we clarify…
…rest in interstate commerce. III The Government argues the Hornes may seek just compensation under the Tucker Act in the Court of Federal Claims, but this Court
…Court dismissed without prejudice Brandt's separate counterclaim for just compensation. Brandt then filed a takings claim in the
Footnotes : Arkansas water law is barely discussed in the parties’ briefs, see Brief for United States
…State of Vermont (the “State”), claiming an interest in the properties involved, intervened and, under the joinder rules of the Court of Federal Claims, entered its appearance as a co-defendant. The
Yes. Federal Rule of Evidence 1101(a) expressly lists the Court of Federal Claims among the courts in which the rules govern. The rules therefore control admissibility determinations in ordinary civil damages actions filed there. Administrative proceedings that preceded the court action do not exempt evidence from the rules once it is offered in the Court of Federal Claims.
Appeals from final judgments of the Court of Federal Claims are taken to the United States Court of Appeals for the Federal Circuit. That court exercises exclusive appellate jurisdiction over such cases under 28 U.S.C. § 1295. Interlocutory orders granting injunctions are also immediately appealable to the Federal Circuit under 28 U.S.C. § 1292(c)(1).
Yes. Section 1292(c)(1) authorizes the Federal Circuit to hear appeals from interlocutory injunction orders in cases within its § 1295 jurisdiction. The appeal proceeds even though the underlying action remains pending in the trial court. A motion to dismiss the appeal as premature is therefore denied when the order grants injunctive relief.