Nelson v. United States

United States Court of Federal Claims·Decided March 17, 2026·No. 25-1543·Unpublished

Opinion

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

NOT FOR PUBLICATION

)

LUCAS RANDALL NELSON, )

)

Plaintiff, ) No. 25-1543 )

v. ) Filed: March 17, 2026 )

THE UNITED STATES, )

)

Defendant. )

______________________________________ )

MEMORANDUM OPINION AND ORDER Plaintiff Lucas Randall Nelson, proceeding pro se, filed this breach of contract action against the United States. According to Plaintiff, by failing to process Plaintiff’s GSA-Form Bonds and discharge his commercial paper liability related to his criminal conviction in Texas state court, the Government breached Plaintiff’s alleged contract with the U.S. Department of the Treasury (“U.S. Treasury”). The Government moved to dismiss Plaintiff’s Complaint pursuant to Rule 12(b)(1) of the Rules of the United States Court of Federal Claims (“RCFC”), arguing that Plaintiff failed to put forth a well-pleaded allegation that he entered into a contract with the United States. In response, Plaintiff moved to strike the Government’s motion as frivolous. For the reasons stated below, the Court GRANTS the Government’s Motion to Dismiss and DENIES Plaintiff’s Motion to Strike.

I. BACKGROUND

On September 17, 2025, Plaintiff filed his Complaint seeking relief for an alleged breach of contract. Pl.’s Compl., ECF No. 1. In addition to the United States, the Complaint names as defendants: the State of Texas, numerous state and county officials in Texas, and a private defense

attorney. See id. at 1. Presumably, these defendants were all involved in Plaintiff’s state court criminal prosecution, conviction, and subsequent incarceration. Plaintiff also names the U.S. Attorney for the Southern District of Texas, as well as a magistrate judge and the Clerk of Court in the U.S. District Court for the Southern District of Texas, where Plaintiff’s application for a writ of habeas corpus was considered and denied.1 As best the Court can discern, Plaintiff’s Complaint alleges that he tendered “GSA-Form Bonds” to the United States to discharge “outstanding commercial paper liability” that Plaintiff believes is tied to his criminal conviction. See id. at 6–7; see also Pl.’s Compl., Ex. 2 at 56, ECF No. 1-2 (attaching a purported $100,000,000 “self backed bond based on [Plaintiff’s] future earnings” (capitalization removed)); Pl.’s Resp. to Mot. to Dismiss and Mot. to Strike Gov’t’s Mot. to Dismiss with Mem. of Law in Supp. at 9–10, ECF No. 10 (clarifying that Plaintiff allegedly presented GSA-Form Bonds “through Global Solutions Limited Company (UK)” to discharge “commercial paper liabilities . . . for penal sums codified at Title 27 CFR §72.11 ‘commercial crimes’ defined and/or those commercial crimes found in the Hobbs Act” (emphasis omitted)). The United States allegedly “failed to perform discharge” and thus breached its purported contract with Plaintiff. ECF No. 1 at 7. Plaintiff accordingly contends that the Court has Tucker Act jurisdiction to hear his breach of contract claim. See id. at 2. In addition to this contractual theory, Plaintiff alleges that the Court has jurisdiction because “there exists an issue as to setoff in the relation between Plaintiff and a fiscal agent of the United States . . . pursuant to Title 28 USC §1503 – setoffs.” Id. (citation modified).

1 Plaintiff originally filed his habeas petition in the U.S. District Court for the Western District of Texas, which transferred the petition to the Southern District. See Nelson v. Collier, No. 6:25-cv-00208 (W.D. Tex. May 19, 2025), ECF No. 7.

Plaintiff does not seek monetary relief for his claims; rather, he asks the Court to: (1)

require that “the bonds tendered in accord with . . . [Plaintiff’s] [c]ontract with the U.S. Treasury[] be honored, processed, and acknowledged;” (2) order Plaintiff’s release from incarceration; (3) “[p]rovide plaintiff a full final accounting, a 1099, a ‘zero balance due’ document if d/b/a defendant is a Clerk of Court in a Court (civil or criminal);” and (4) “[p]lace the ‘d/b/a defendant’ on probation due to their inability or unwillingness or ignorance as to their failure to process, discharge, and release plaintiff from all commercial liability(ies) at issue.” Id. at 8 (emphases in original).

The Government moved to dismiss Plaintiff’s Complaint for lack of subject-matter jurisdiction on November 14, 2025. Gov’t’s Mot. to Dismiss for Lack of Subject Matter Jurisdiction, ECF No. 8. According to the Government, Plaintiff fails to allege sufficient facts to show the existence of a valid contract with the United States. Id. at 3. The Government emphasizes the lack of any factual allegations demonstrating intent by the United States to enter into a contract with Plaintiff and notes that Plaintiff’s Complaint utilizes sovereign citizen tactics. Id. at 4–6. In response to Plaintiff’s attempt to invoke this Court’s set-off jurisdiction under § 1503, the Government argues that such jurisdiction only extends to counterclaims brought by the United States and is thus irrelevant here, where no such counterclaim has been made. Id. at 6– 7.

Plaintiff filed his response by leave of the Court on December 19, 2025. See ECF No. 10.

In his response, Plaintiff disputes that the Court lacks subject-matter jurisdiction, emphasizing that the deposit of his birth certificate in the U.S. Treasury via a Treasury Direct Account established a contractual relationship between Plaintiff and the United States. See id. at 2–5. Plaintiff’s response further requests that the Court (1) “acknowledge that plaintiff is a secured party in relation

to defendant,” (2) “enforce the discharge for plaintiff’s commercial paper liabilities,” (3) “strike defendant’s Answer in the Form of a Motion to Dismiss,” and (4) “grant plaintiff’s requested relief in the Complaint.” Id. at 21 (emphasis in original).

On January 6, 2026, the Government filed a reply, reiterating its argument that Plaintiff’s allegations “fail to show the existence of a valid contract between the plaintiff and the United States,” and further contending that the statutes and regulations cited by Plaintiff are not money- mandating. Gov’t’s Reply in Supp. of Mot. to Dismiss for Lack of Subject Matter Jurisdiction at 2, ECF No. 11. The Government also claims that Plaintiff’s Motion to Strike is improper, as such a motion may only be directed at a pleading. Id. at 3. Plaintiff did not file a reply in support of his Motion to Strike. The Government’s Motion to Dismiss and Plaintiff’s Motion to Strike are both ripe for the Court’s review.

II. LEGAL STANDARDS

A. Dismissal for Lack of Jurisdiction The United States Court of Federal Claims is a court of limited jurisdiction. Massie v.

United States, 226 F.3d 1318, 1321 (Fed. Cir. 2000). Before the Court can reach the merits of a plaintiff’s claim, it must first assure itself of the existence of subject-matter jurisdiction. See Ruhrgas AG v. Marathon Oil Co., 526 U.S. 574, 583 (1999). If the Court lacks subject-matter jurisdiction, it must dismiss the action. RCFC 12(h)(3); see also RCFC 12(b)(1). The Court’s power to hear a case “may be challenged at any time by the parties or by the court.” Folden v. United States, 379 F.3d 1344, 1354 (Fed. Cir. 2004) (citing Fanning, Phillips & Molnar v. West, 160 F.3d 717, 720 (Fed. Cir. 1998)). While the Court holds pro se plaintiffs to a less stringent standard than plaintiffs with attorney representation, pro se plaintiffs still bear the burden of establishing the Court’s jurisdiction by a preponderance of the evidence. See Riles v. United States,

93 Fed. Cl. 163, 165 (2010) (citing Hughes v. Rowe, 449 U.S. 5, 9 (1980); Taylor v. United States, 303 F.3d 1357, 1359 (Fed. Cir. 2002)).

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