Also known as: U.S. Claims Court · United States Claims Court · Court of Federal Claims
Written by attorneys — see sources below.
A specialized federal court of record established under Article I of the Constitution with exclusive jurisdiction to hear monetary claims against the United States. The court applies the Federal Rules of Evidence in its civil proceedings.
Atlas Hedge Fund filed a civil action in the United States Court of Federal Claims against the Office of the Comptroller of Finance seeking damages for wrongful denial of a federal banking license. At a pretrial conference the regulator argued that relaxed administrative standards should continue to control admissibility. The court applied the Federal Rules of Evidence to determine whether prior hearing transcripts could be admitted.
Cobalt Energy sued the United States in the Court of Federal Claims for breach of a procurement contract. The trial judge issued an interlocutory order containing a controlling-question certification. The Federal Circuit exercised discretion to hear the appeal from that order.
Following the 1978 amendments to the Federal Insecticide, Fungicide, and Rodenticide Act, the Environmental Protection Agency gained authority to consider data submitted by one registrant to support the registration of pesticides by follow-on applicants, provided the applicant offers compensation to the original data submitter. If the parties fail to agree on the amount of compensation, either may initiate binding arbitration, and the arbitrator's findings are final except for review based on fraud, misrepresentation, or other misconduct. Appellees are thirteen large firms that had submitted research data to the EPA for pesticide registrations. After the 1978 amendments took effect, the firms filed suit in the Southern District of New York challenging the data-consideration and compensation provisions on constitutional grounds, later amending the complaint to include an Article III claim regarding the arbitration mechanism. The district court granted appellees' motion for summary judgment on their Article III claims. The District Court, rather than striking down the statutory limitation on judicial review, enjoined the entire FIFRA data use and compensation scheme. The Supreme Court vacated that judgment and remanded the case for reconsideration in light of its decision in Ruckelshaus v. Monsanto Co. On remand in this case, appellees amended their complaint to reflect that EPA had, in fact, considered their data in support of other registration applications. The amended complaint also alleged that data submitted by appellee Stauffer Chemical Company had been used in connection with registrations by PPG Industries, Inc., and Drexel Chemical Company. Stauffer had invoked the arbitration provisions of § 3(c)(1)(D)(ii) against PPG, and appellees entered in evidence the award of the arbitration panel, handed down on June 28, 1983. The district court reinstated its prior judgment enjoining the operation of the data-consideration provisions as violative of Article III. The Supreme Court noted probable jurisdiction on EPA's direct appeal.
View caseCedar Creek Farms brought an action in the Court of Federal Claims alleging that temporary flooding caused by federal flood-control operations effected a taking of its property. The court exercised jurisdiction to decide whether the government action constituted a compensable taking.
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.
View caseThe Marvin M. Brandt Revocable Trust sued the United States in the Court of Federal Claims asserting ownership of land subject to an abandoned railroad right-of-way. The court resolved the competing claims to title under the governing federal land-grant statutes.
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.
View caseHorne, a raisin grower, filed suit in the Court of Federal Claims contending that a federal marketing order requiring surrender of a portion of the crop effected a physical taking. The court addressed whether the mandated transfer of specific property constituted a per se taking.
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.
View caseEastern Enterprises sued the United States in the Court of Federal Claims asserting that the Coal Act's retroactive premium obligations violated the Takings Clause. The court examined whether the statutory scheme effected an unconstitutional taking of the company's property.
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.
View caseYes. Federal Rule of Evidence 1101(a) expressly lists the United States Court of Federal Claims among the courts in which the rules govern proceedings. The rules therefore control admissibility determinations in civil actions filed in that court.
Supporting sources
Congress established the court as an Article I tribunal under 28 U.S.C. § 171(a). It possesses jurisdiction to render judgment on monetary claims against the United States, including contract and takings claims.
Supporting sources
Yes. Under 28 U.S.C. § 1292(d)(2) the Federal Circuit may permit an appeal from an interlocutory order of the Court of Federal Claims when the order contains the required certification of a controlling question of law.
Supporting sources