Fowler v. United States

CourtUnited States Court of Federal Claims
DecidedNovember 18, 2024
Docket24-857
StatusUnpublished

This text of Fowler v. United States (Fowler 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
Fowler v. United States, (uscfc 2024).

Opinion

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

NOT FOR PUBLICATION ______________________________________ ) ERIC ORLANDO FOWLER, ) ) Plaintiff, ) No. 24-857 ) v. ) Filed: November 18, 2024 ) THE UNITED STATES, ) ) Defendant. ) ______________________________________ )

MEMORANDUM OPINION AND ORDER

This action concerns Plaintiff Eric Orlando Fowler’s bond proceedings in state court and

alleged violations by state and federal officials of various statutory and constitutional provisions.

Mr. Fowler appears to argue that the State of Florida illegally seized his property during the bond

proceedings. He further appears to allege that the “Alien Property Custodian,” Attorney General

of the United States, and the “United States Treasurer” have violated his rights under the Trading

with the Enemy Act, 50 U.S.C. § 4301 et seq. Before the Court is the Government’s Motion to

Dismiss pursuant to Rules 12(b)(1) and 12(b)(6) of the Rules of the United States Court of Federal

Claims (“RCFC”). For the reasons set forth below, the Court GRANTS the Government’s Motion.

I. BACKGROUND

On June 4, 2024, Mr. Fowler, who is currently incarcerated at the Northwest Florida

Reception Center and is proceeding pro se, filed this civil action against numerous state officials

and entities, including the Governor of Florida, Ron DeSantis; the Chief Financial Officer of the

Florida Department of Financial Services; the Florida Department of Revenue; and Judge Mary M. Handsel, as well as the Clerk of Court, of the Sixth Judicial Circuit of Florida. 1 See Pl.’s

Compl., ECF No. 1. He asserts an array of claims, all of which appear related to an April 2018

bond or forfeiture proceeding, during which he alleges the State of Florida seized his property.

See id. at 3.

Mr. Fowler alleges that the state defendants committed “criminal offense(s)” by (1) making

“illegal contracts,” (2) seizing property with “imperfected title,” (3) making fraudulent property

claims, (4) engaging in fraudulent concealment, (5) illegally withholding title, (6) usurping and

unlawfully seizing Mr. Fowler and his property, (7) being unjustly enriched, (8) fraudulently

conveying Mr. Fowler’s property, (9) engaging in fraud, (10) engaging in “inequitable conduct,”

(11) breaching “trust” with fraudulent intent, (12) abuse and misrepresenting their powers, (13)

unlawfully detaining Mr. Fowler, (14) violating Mr. Fowler’s due process rights, and (15) “actions

of wrong doing without just compensation (against the 5th amend. of civilian due process of law).”

Id. Later in Mr. Fowler’s Complaint, he cites to Section 1 of the Fourteenth Amendment for the

definition of “citizen,” asserting that he has “unalienable rights to private property.” Id. at 4.

Property rights within Section 1 of the Fourteenth Amendment appear in the Due Process Clause.

See U.S. Const. amend. XIV, § 1 (prohibiting states from depriving “any person of life, liberty, or

property, without due process of law”).

Because Mr. Fowler has filed at least three federal complaints that were dismissed as

frivolous, malicious, or for failure to state a claim, he is barred under the three-strikes rule from

proceeding in forma pauperis (“IFP”). See 28 U.S.C. § 1915(g); Order Directing Payment of Fee,

ECF No. 5. On June 10, 2024, the Court directed Mr. Fowler to pay the filing fee necessary to

1 In his Response to the Government’s Motion to Dismiss, Mr. Fowler changed the caption to include the “United States Treasurer, Alien Property Custodian, [and] Merrick Garland,” Attorney General of the United States, as defendants. Resp. to Mot. to Dismiss at 1, ECF No. 18. 2 proceed with his action or risk dismissal under RCFC 41 for failure to prosecute his case. See ECF

No. 5. The Court received his filing fee on June 28, 2024. The Government filed its Motion to

Dismiss on August 1, 2024, arguing that this Court does not have jurisdiction to hear Mr. Fowler’s

claims and, in the alternative, that the Complaint fails to state a claim. See Mot. to Dismiss, ECF

No. 8.

After the Government moved to dismiss, Mr. Fowler submitted several filings—some of

which the Court rejected as deficient, see Orders, ECF Nos. 7, 11—that failed to respond to the

Government’s Motion to Dismiss or the arguments contained therein. See Cause of Action, ECF

No. 10; Suit in Equity Demand for En Banc Strike Dismissal, ECF No. 13; Notice Rejecting

Deficiency Mem., ECF No. 15. On September 9, 2024, the Court ordered Mr. Fowler to file a

response to the Government’s Motion by no later than September 23, 2024, or risk dismissal of

his action for failure to prosecute. See Order Directing Resp., ECF No. 16. On September 24,

2024, the Court received Mr. Fowler’s “Response to Order Dated 9/9/24,” which the Court

construed as a Response to the Government’s Motion to Dismiss. See Resp. to Mot. to Dismiss,

ECF No. 18; Order Permitting Filing, ECF No. 17. Pursuant to the Court’s order, the Government

filed its Reply on October 10, 2024. See Reply, ECF No. 20. Following the close of briefing, Mr.

Fowler filed a motion to “strike defendant’s second motion to dismiss,” see ECF No. 22, which

the Court construed as a Sur-Reply and permitted Mr. Fowler to file. 2 See Order, ECF No. 21.

2 Much of the motion appears to respond to the Government’s arguments in its Motion to Dismiss. See, e.g., ECF No. 22 at 1–2 (“[A]lthough this federal claims court is article I, because as a private Citizen mentioned in the trading with the enemy act (§ 9), [I] am now bound to the president, treasurer, and alien property custodian, and article III the rightful, lawful setting and constitutionally protected.”). However, citing 28 U.S.C. § 173, it also includes a request for a change of venue. Id. at 2. Since the Court in its discretion has determined that oral argument would not assist it in resolving the Government’s Motion, it is not necessary to consider whether any court proceedings should be held in the United States District Court for the Northern District 3 II. LEGAL STANDARDS

A. Pro Se Litigants

The Court liberally construes allegations in complaints filed by pro se litigants. See

Whiting v. United States, 99 Fed. Cl. 13, 15 (2011); Durr v. Nicholson, 400 F.3d 1375, 1380 (Fed.

Cir. 2005). Despite this leniency, pro se litigants must still meet the same jurisdictional

requirements that apply to all litigants. Kelley v. Sec’y, U.S. Dep’t of Lab., 812 F.2d 1378, 1380

(Fed. Cir. 1987); see also Knighten v. United States, No. 2024-1563, 2024 WL 4457474, at *1

(Fed. Cir. Oct. 10, 2024) (“[T]his principle does not relieve an unrepresented plaintiff of the

obligation to establish jurisdiction.”). Regardless of pro se status, a plaintiff always bears the

burden of establishing subject-matter jurisdiction. See Estes Express Lines v. United States, 739

F.3d 689, 692 (Fed. Cir. 2014); Reynolds v. Army & Air Force Exch. Serv., 846 F.2d 746, 748

(Fed. Cir. 1988).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Ex Parte McCardle
74 U.S. 506 (Supreme Court, 1869)
Rawlings v. Ray
312 U.S. 96 (Supreme Court, 1941)
United States v. Sherwood
312 U.S. 584 (Supreme Court, 1941)
United States v. Mitchell
463 U.S. 206 (Supreme Court, 1983)
Hercules, Inc. v. United States
516 U.S. 417 (Supreme Court, 1996)
Ruhrgas Ag v. Marathon Oil Co.
526 U.S. 574 (Supreme Court, 1999)
Franconia Associates v. United States
536 U.S. 129 (Supreme Court, 2002)
Souders v. South Carolina Public Service Authority
497 F.3d 1303 (Federal Circuit, 2007)
John R. Sand & Gravel Company v. United States
457 F.3d 1345 (Federal Circuit, 2006)
Moden v. United States
404 F.3d 1335 (Federal Circuit, 2005)
Durr v. Nicholson
400 F.3d 1375 (Federal Circuit, 2005)
Gene A. Williams v. Secretary of the Navy
787 F.2d 552 (Federal Circuit, 1986)
Donna Kelley v. Secretary, U.S. Department of Labor
812 F.2d 1378 (Federal Circuit, 1987)
Tabb Lakes, Ltd. v. United States
10 F.3d 796 (Federal Circuit, 1993)

Cite This Page — Counsel Stack

Bluebook (online)
Fowler v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/fowler-v-united-states-uscfc-2024.