Sharp v. Department of Veteran Affairs, Board of Appeals

CourtDistrict Court, District of Columbia
DecidedFebruary 14, 2025
DocketCivil Action No. 2024-1345
StatusPublished

This text of Sharp v. Department of Veteran Affairs, Board of Appeals (Sharp v. Department of Veteran Affairs, Board of Appeals) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Sharp v. Department of Veteran Affairs, Board of Appeals, (D.D.C. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

ANTHONY SHARP,

Plaintiff.

v. Nos. 24-cv-01345 (DLF) 24-cv-01144 (DLF) DEPARTMENT OF VETERAN AFFAIRS, BOARD OF APPEALS,

Defendant.

MEMORANDUM OPINION AND ORDER

Before the Court is the Department of Veteran Affairs, Board of Appeals’ (“Board”)

Motion to Dismiss this consolidated action under Federal Rules of Civil Procedure 12(b)(1) and

12(b)(6). Dkt. 6. For the reasons that follow, the Court will grant the Board’s motion and dismiss

this case for lack of jurisdiction under Rule 12(b)(1).

I. BACKGROUND

On August 21, 2023, Mr. Sharp, a prisoner proceeding pro se, filed suit against the

American Legion and James E. Jackson in D.C. Superior Court for legal malpractice arising out

of their representation of Mr. Sharp in administrative proceedings before the Board of Veterans’

Appeals. See Compl., at 1, 5, Sharp v. American Legion, 2023-CAB-005322 (D.C. Super. Ct.

Aug. 21, 2023). On December 21, 2023, Sharp filed a subpoena with the Superior Court asking

the Board to produce various documents by February 2, 2024. See Subpoena, American Legion,

2023-CAB-00532 (D.C. Super. Ct. Dec. 21, 2023). Thereafter, on March 25, 2024, Sharp

amended his complaint, naming the Board as a defendant and seeking $20,000 for the Board’s

alleged failure to comply with the subpoena, as well as $500 for each day the Board remains in non-compliance. See Am. Compl. at 1, American Legion, 2023-CAB-00532 (D.C. Super. Ct. Mar.

25, 2024).

Subsequently, Sharp brought two separate actions against the Board in D.C. Superior

Court, both seeking damages for the Board’s non-compliance with the subpoena in 2023-CAB-

00532. The first action sought $20,000 plus $500 for each day that the Board continued to be non-

compliant with the subpoena. See Sharp v. Dep’t of Veteran Affs., Bd. of Appeals, No. 24-cv-1144

(D.D.C.), Compl., Dkt. 1-1. The second sought $8,500 for the Board’s failure to comply with the

subpoena. See Sharp v. Dep’t of Veteran Affs., Bd. of Appeals, No. 24-cv-1345 (D.D.C), Compl.,

Dkt. 1-1. Sharp marked the first action as an administrative proceeding petition, see No. 24-cv-

1144, Compl. at 3, and the second action as a tort suit for negligence, see No. 24-cv-1345, Compl.

at 6.

The Board properly removed the complaints pursuant to 28 U.S.C. § 1442(a)(1). 1 See No.

24-cv-1144, Notice of Removal, Dkt. 1; No. 24-cv-1345, Notice of Removal, Dkt. 1. The Board

then moved to consolidate the two actions. See No. 24-cv-1144, Mot. to Consolidate, Dkt. 5; No.

24-cv-1345, Mot. to Consolidate, Dkt. 4. The Court granted the latter motion and consolidated the

two complaints into the instant matter. See Minute Order of June 18, 2024.

The defendant moves to dismiss for lack of subject matter jurisdiction and for failure to

state a claim. Dkt. 6.

1 28 U.S.C. § 1442(a)(1) permits removal of a civil action commenced in a State court against an agency of the United States relating to “any act under color of such office.” § 1442(a)(1). “An act under color of such office requires removal to be predicated on the allegation of a colorable federal defense.” In re Subpoena in Collins, 524 F.3d 249, 251 (D.C. Cir. 2008). Because the Board raises sovereign immunity as a defense, that standard is met here. See id.; Mot. to Dismiss at 5.

2 II. LEGAL STANDARDS

Under Federal Rule of Civil Procedure 12(b)(1), a defendant may move to dismiss an action

for lack of subject-matter jurisdiction. Fed. R. Civ. P. 12(b)(1). Because “[s]overeign immunity is

jurisdictional in nature,” FDIC v. Meyer, 510 U.S. 471, 475 (1994), claims barred by the United

States’ sovereign immunity are “subject to dismissal under Rule 12(b)(1),” Clayton v. District of

Columbia, 931 F. Supp. 2d 192, 200 (D.D.C. 2013). When reviewing a motion to dismiss for lack

of jurisdiction, the court must “assume the truth of all material factual allegations in the complaint

and construe the complaint liberally.” Am. Nat. Ins. Co. v. FDIC, 642 F.3d 1137, 1139 (D.C. Cir.

2011) (internal quotation marks omitted). At the same time, plaintiffs bear the burden of

establishing subject-matter jurisdiction, see Arpaio v. Obama, 797 F.3d 11, 19 (D.C. Cir. 2015),

and courts must raise obstacles to their jurisdiction sua sponte, see Fort Bend Cty. v. Davis, 587

U.S. 541, 548 (2019). “[W]hile complaints filed by pro se litigants are held to a less stringent

standard than those applied to formal pleadings drafted by lawyers, even a pro se plaintiff bears

the burden of establishing that the Court has subject matter jurisdiction.” Newby v. Obama, 681

F. Supp. 2d 53, 55 (D.D.C. 2010) (cleaned up).

III. ANALYSIS

As an initial matter, it is difficult to discern the cause of action underlying Sharp’s suit.

Sharp marked his complaint as a suit for negligence, see Compl. at 6, and the Board interpreted

the claim as arising under the Federal Tort Claims Act (“FTCA”), 28 U.S.C. § 1346, see Mot. to

Dismiss at 5. In his opposition and sur-reply, however, Sharp insists that he does not raise a

negligence claim. See Opp’n, Dkt. 8, at 4; Sur-Reply, Dkt. 10, at 2. Rather, he claims the Board

is in contempt of court due to its failure to comply with the subpoena, rendering him entitled to

damages. See Compl., Dkt. 1-1, at 1; Opp’n at 4–5. The Court will liberally construe Sharp’s

3 complaint and consider both possibilities. See Dougherty v. United States, 156 F. Supp. 3d 222,

230 (D.D.C. 2016) (“It is well established that the pleadings of pro se parties are to be ‘liberally

construed.’” (quoting Erickson v. Pardus, 551 U.S. 89, 94 (2007)).

Construing the complaint as a negligence action under the FTCA, there are several

jurisdictional defects. First, while the FTCA waives the United States’ immunity for certain tort

claims, 28 U.S.C. § 1346(b)(1), it does not waive sovereign immunity for suits against specific

agencies, see Coulibaly v. Kerry, 213 F. Supp. 3d 93, 125 (D.D.C. 2016). Because Sharp names

the Board, rather than the United States, as the defendant, he cannot establish a waiver of sovereign

immunity under the FTCA. See id.

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Related

Arizona v. Manypenny
451 U.S. 232 (Supreme Court, 1981)
McNeil v. United States
508 U.S. 106 (Supreme Court, 1993)
Federal Deposit Insurance v. Meyer
510 U.S. 471 (Supreme Court, 1994)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
In Re Subpoena in Collins
524 F.3d 249 (D.C. Circuit, 2008)
American Nat. Ins. Co. v. FDIC
642 F.3d 1137 (D.C. Circuit, 2011)
Newby v. Obama
681 F. Supp. 2d 53 (District of Columbia, 2010)
Santini v. Herman
456 F. Supp. 2d 69 (District of Columbia, 2006)
Clayton v. District of Columbia
931 F. Supp. 2d 192 (District of Columbia, 2013)
Merkulov v. United States Park Police
75 F. Supp. 3d 126 (District of Columbia, 2014)
Joseph Arpaio v. Barack Obama
797 F.3d 11 (D.C. Circuit, 2015)
Dougherty v. United States
156 F. Supp. 3d 222 (District of Columbia, 2016)
Coulibaly v. Kerry
213 F. Supp. 3d 93 (District of Columbia, 2016)

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