Bracken v. United States

CourtUnited States Court of Federal Claims
DecidedJuly 1, 2026
Docket25-2192
StatusPublished

This text of Bracken v. United States (Bracken v. United States) is published on Counsel Stack Legal Research, covering United States Court of Federal Claims primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bracken v. United States, (uscfc 2026).

Opinion

In the United States Court of Federal Claims No. 25-2192 Filed: July 1, 2026

GARVESTER BRACKEN,

Plaintiff,

v.

THE UNITED STATES,

Defendant.

ORDER

TAPP, Judge.

The Court received Plaintiff Garvester Bracken’s (“Mr. Bracken”) Complaint on August 4, 2025. (Compl., ECF No. 1). Mr. Bracken’s Complaint arises from a petition for a writ of habeas corpus he filed in the United States Supreme Court in May of 2021. (Id. at 2 (citing Bracken v. Missouri, No. 20-1660 (2021))). Mr. Bracken alleges that, although he attempted to file as an indigent person, employees of the Supreme Court required him to pay the standard $300.00 filing fee. (Id. at 2–3). Mr. Bracken now seeks a return of that fee. However, in this present action, Mr. Bracken has neither paid the necessary filing fee nor submitted a request to proceed without prepayment. See 28 U.S.C. §§ 1914, 1915. 1 Furthermore, the Court concludes that allowing Mr. Bracken to pursue this matter would be futile since his claims fall outside the Court’s jurisdiction. Put simply, even had Mr. Bracken complied with this Court’s procedural requirements, the Court still could not have reached the merits of his claims. Accordingly, his Complaint must be DISMISSED.

Before addressing the substance of Mr. Bracken’s claims, the Court must first confront the significant delay between his initial submission and the issuance of this dismissal. On June

1 Even if incarcerated individuals are granted leave to proceed in forma pauperis, they remain obligated to pay this Court’s $350.00 filing fee over time, beginning with an initial partial payment and followed by monthly deductions from the prisoner’s institutional account. 28 U.S.C. § 1915(b). Mr. Bracken is currently incarcerated at the Missouri Eastern Correctional Center. (Letter Ex. 1, ECF No. 2-1 (listing Mr. Bracken’s return address)). Thus, even if Mr. Bracken were granted in forma pauperis status, he would ultimately find himself in the same position here as he does before the Supreme Court—required to remit a filing fee he believes is illegitimate. 25, 2026, the Clerk’s Office received an inquiry from Mr. Bracken regarding the status of his case. (Letter, ECF No. 2). Due to an inadvertent administrative error, his Complaint was not processed, and the matter was neither formally opened nor assigned. (Id.). Once this oversight was discovered, the Clerk’s Office promptly docketed the Complaint with a retroactive filing date to preserve the original date of receipt and ensure that Mr. Bracken suffered no legal prejudice. (Id.; Compl.). The case was then assigned to the undersigned on June 29, 2026. (Notice of Random Assignment, ECF No. 3). The Court acknowledges and regrets this delay, particularly in light of the fact that it ultimately lacks jurisdiction over Mr. Bracken’s suit. The Court offers its sincerest apology to Mr. Bracken for the administrative error and the inconvenience it may have caused.

The Court now turns to the threshold issues implicated by Mr. Bracken’s claims. The United States Court of Federal Claims is a specialty court. Terran ex rel. Terran v. Sec’y of Health & Hum. Servs., 195 F.3d 1302, 1309 (Fed. Cir. 1999). Under the Tucker Act, this Court has the authority to hear any non-tort monetary claims against the United States if they are based on the Constitution, federal statutes, executive regulations, or government contracts. 28 U.S.C. § 1491(a)(1). To invoke the Court of Federal Claims’ limited jurisdiction for a legal violation, the underlying provision must be “money-mandating,” meaning it “can fairly be interpreted as mandating compensation by the Federal Government for the damage sustained.” United States v. Testan, 424 U.S. 392, 400 (1976). This money-mandating source of law must be distinct from the Tucker Act itself. United States v. Navajo Nation, 556 U.S. 287, 289–90 (2009). The Court “may and should” review the question of its subject-matter jurisdiction on its own “at any time it appears in doubt.” Arctic Corner, Inc. v. United States, 845 F.2d 999, 1000 (Fed. Cir. 1988) (citation omitted); see also OTI Am., Inc. v. United States, 68 Fed. Cl. 108, 113 (2005) (“Jurisdiction must be established as a threshold matter before the court may proceed with the merits” of any action.) (citing Steel Co. v. Citizens for a Better Env’t, 523 U.S. 83, 88–89 (1998)); RCFC 12(h)(3) (“If the court determines at any time that it lacks subject-matter jurisdiction, the court must dismiss the action.”).

The Court acknowledges that pro se plaintiffs are not expected to frame issues with the precision of attorneys. Roche v. U.S. Postal Service, 828 F.2d 1555, 1558 (Fed. Cir. 1987). In conducting its review, the Court also accepts as true all undisputed facts in pleadings and draws all reasonable inferences in favor of the plaintiff. Trusted Integration, Inc. v. United States, 659 F.3d 1159, 1163 (Fed. Cir. 2011). However, even pro se plaintiffs “must persuade the Court that jurisdictional requirements have been met.” Bernard v. United States, 59 Fed. Cl. 497, 499 (2004), aff’d, 98 F. App’x 860 (Fed. Cir. 2004); see also Zulueta v. United States, 553 F. App’x 983, 985 (Fed. Cir. 2014) (“[T]he leniency afforded to a pro se litigant with respect to mere formalities does not relieve the burden to meet jurisdictional requirements.” (quotation and citation omitted)).

Mr. Bracken’s Complaint suffers from three fundamental and insurmountable jurisdictional defects. First, among the various requirements for establishing jurisdiction, a plaintiff must sue the correct party. See U.S. ex rel. Long v. SCS Bus. & Tech. Inst., Inc., 173 F.3d 890, 894 (D.C. Cir. 1999) (“The determination of whether a particular action is properly asserted against a [party] is also a kind of logical prerequisite to the jurisdictional inquiry.”). It is well settled that the United States is the only proper defendant in the Court of Federal Claims. United States v. Sherwood, 312 U.S. 584, 588 (1941); see also RCFC 10 (“The title of the

2 complaint must name all the parties . . . with the United States designated as the party defendant”). Put simply, to invoke this Court’s jurisdiction, the defendant must—without exception—be the United States. 28 U.S.C. § 1491(a)(1); RCFC 10(a). Mr. Bracken expressly states that his claims are directed at a “bond of [ ] Defendants who are federal employees.” (Compl. at 1). Because his claims are not brought against the United States, they fall outside the scope of this Court’s jurisdiction. Stephenson v. United States, 58 Fed. Cl.

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Related

United States v. Sherwood
312 U.S. 584 (Supreme Court, 1941)
United States v. Testan
424 U.S. 392 (Supreme Court, 1976)
Bounds v. Smith
430 U.S. 817 (Supreme Court, 1977)
Pilson v. Bordenkircher
444 U.S. 1 (Supreme Court, 1979)
United States v. Navajo Nation
556 U.S. 287 (Supreme Court, 2009)
Wopsock v. Natchees
454 F.3d 1327 (Federal Circuit, 2006)
Eastport Steamship Corporation v. The United States
372 F.2d 1002 (Court of Claims, 1967)
Panko v. Rodak
606 F.2d 168 (Seventh Circuit, 1979)
Ronald J. Roche v. United States Postal Service
828 F.2d 1555 (Federal Circuit, 1987)
Arctic Corner, Inc. v. The United States
845 F.2d 999 (Federal Circuit, 1988)
Trusted Integration, Inc. v. United States
659 F.3d 1159 (Federal Circuit, 2011)
Roynell Joshua v. The United States, on Motion
17 F.3d 378 (Federal Circuit, 1994)
Allustiarte v. United States
256 F.3d 1349 (Federal Circuit, 2001)
Ian Owen Sharpe v. the United States 1
112 Fed. Cl. 468 (Federal Claims, 2013)
Lewis v. Green
629 F. Supp. 546 (District of Columbia, 1986)
United States v. Choi
818 F. Supp. 2d 79 (District of Columbia, 2011)
Steel Co. v. Citizens for a Better Environment
523 U.S. 83 (Supreme Court, 1998)
Zulueta v. United States
553 F. App'x 983 (Federal Circuit, 2014)

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