Talley v. United States Department of Veterans Affairs

District Court, W.D. Washington·Decided May 14, 2025·No. 2:24-cv-00355·Unknown

Opinion

1 2 3

4 5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 7 CHARLES ELLIS TALLEY, CASE NO. C24-0355-KKE 8

Plaintiff, ORDER ON PENDING MOTIONS 9 v.

10 UNITED STATES VETERANS AFFAIRS,

11 Defendant.

12 Plaintiff Charles Ellis Talley brings this civil rights case against Defendant United States 13 Department of Veterans Affairs (“VA”) alleging various errors in the adjudication of his veterans’ 14 benefits. Dkt. No. 28. Defendant moves to dismiss the case for lack of subject matter jurisdiction 15 and for being outside the relevant statute of limitations. Dkt. No. 29. After consideration of the 16 parties’ briefing, the complete record, and the relevant case law, the Court agrees that it does not 17 have subject matter jurisdiction over this case. 18 I. BACKGROUND 19 This case arises out of Mr. Talley’s claim for veterans’ benefits, as a result of his service 20 in the United States Army from 1967–1969. Dkt. No. 28 at 2. Mr. Talley was initially discharged 21 under “other than honorable” conditions, a characterization he alleges was erroneous. Id. In 1977, 22 his discharge was upgraded to “under honorable conditions” pursuant to a Special Discharge 23 Review Program. Id. at 2, 13. He applied for veterans benefits in 1978, but was denied them 24 1 pursuant to Public Law 95-126 (id.), a statute intended to deny entitlement to benefits to certain 2 persons who would otherwise be eligible “solely by virtue of the administrative upgrading” of 3 other than honorable discharges. Pub. L. No. 95-126, 91 Stat 1106. Mr. Talley now seeks to

4 challenge the 1978 Administrative Decision denying his benefits under Public Law 95-126. 5 Mr. Talley initially filed two actions arising from the same set of facts. See Dkt. No. 26. 6 After resolving various motions (Dkt. Nos. 7, 21), consolidating Mr. Talley’s two pending cases 7 into this action (Dkt. No. 26), and ordering Mr. Talley to file an amended consolidated complaint 8 including “[a]ll claims against Defendant” (Dkt. No. 26 at 2), Mr. Talley filed an amended 9 complaint with two claims. Dkt. No. 28. His first claim challenges the substantive reason for the 10 denial of his benefits, namely the administrative decision that his upgraded discharge could not be 11 affirmed for purposes of benefits eligibility (“Claim One”). Id. at 4–5, 13. His second claim 12 alleges that he should have been given an in-person hearing regarding the April 1978 decision

13 denying his benefits (“Claim Two”). Id. at 7. 14 The amended complaint also describes Mr. Talley’s extensive efforts to challenge the 15 conduct alleged in both claims, including appeals to the Board of Veterans Appeals and the U.S. 16 Court of Appeals for Veterans Claims and communicating with elected representatives. Dkt. No. 17 28 at 8. Lastly, Mr. Talley alleges significant harms caused by the Defendant’s allegedly illegal 18 actions. Id. at 4, 9–11. Mr. Talley attached eight exhibits to the amended complaint. Id. at 13– 19 24. 20 Defendant now moves to dismiss the complaint under Federal Rule of Civil Procedure 21 12(b)(1) for lack of subject matter jurisdiction and Rule 12(b)(6) for violating the relevant statutes 22 of limitations. Dkt. No. 29. Mr. Talley filed an opposition (Dkt. No. 301) and Defendant replied 23

1 On the docket this document is referred to as a “cross motion” but Mr. Talley only requests denial of the motion to 24 dismiss. Dkt. No. 30 at 1, Dkt. No. 30-2. 1 (Dkt. No. 31). Mr. Talley then filed a motion to correct certain clerical errors in his opposition 2 which Defendant did not oppose. Dkt. No. 32. Both motions are ripe for the Court’s consideration. 3 II. ANALYSIS

4 A. The Court Grants Mr. Talley’s Motion to Correct Wording. 5 Mr. Talley moves to correct certain language in his opposition brief and Defendant has not 6 opposed this request. Dkt. No. 32. While the first two pages of Mr. Talley’s nine-page filing 7 merely identify clerical errors, his extended “conclusion” includes factual and legal arguments. 8 See id. In light of the leeway afforded to pro se parties, Defendant’s failure to object to this filing, 9 and the considerable overlap between the arguments in the conclusion and Mr. Talley’s timely 10 opposition, the Court grants Mr. Talley’s motion and considers the material included in his 11 extended conclusion. See Huffman v. Lindgren, 81 F.4th 1016, 1021 (9th Cir. 2023) (“There is a 12 good reason that we afford leeway to pro se parties, who appear without counsel and without the

13 benefit of sophisticated representation[.]”). 14 B. The Court Grants Defendant’s Motion to Dismiss for Lack of Subject Matter Jurisdiction. 15 Defendant moves to dismiss pursuant to Federal Rules of Civil Procedure 12(b)(1) and 16 12(b)(6), arguing both that the Court lacks jurisdiction over Plaintiff’s case and that his complaint 17 is time-barred. Dkt. No. 29. Because the Court concludes that it lacks subject matter jurisdiction, 18 the Court will not reach Defendant’s Rule 12(b)(6) arguments. See Priv. Client Fiduciary Corp. 19 v. Chopra, No. 22-CV-00436-LK, 2023 WL 2372917, at *2 (W.D. Wash. Mar. 6, 2023). 20 1. Legal standards 21 “Federal courts are courts of limited jurisdiction. They possess only that power authorized 22 by Constitution and statute[.]” Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375, 377 23 (1994); U.S. CONST. ART. III, § 2. “In cases involving benefits owed to veterans, Congress has 24 1 created a scheme conferring exclusive jurisdiction over claims affecting veterans’ benefits to some 2 federal courts, while denying all other federal courts any jurisdiction over such claims. The source 3 of that statutory scheme is the Veterans’ Judicial Review Act of 1988” (“VJRA”). Veterans for

4 Common Sense v. Shinseki, 678 F.3d 1013, 1020 (9th Cir. 2012). “Congress, in its discretion, has 5 elected to place judicial review of claims related to the provision of veterans’ benefits beyond our 6 reach and within the exclusive purview of the United States Court of Appeals for Veterans Claims 7 and the Court of Appeals for the Federal Circuit.” Id. at 1016 (citing 38 U.S.C. §§ 511, 7252, 8 7292). 9 The VJRA “precludes jurisdiction over a claim if it requires the district court to review VA 10 decisions that relate to benefits decisions, including any decision made by the [VA] in the course 11 of making benefits determinations[.]” Veterans for Common Sense, 678 F.3d at 1025 (cleaned 12 up). “[I]f reviewing [Mr. Talley’s] claim would require review of the circumstances of [his]

13 individual benefits request[], jurisdiction is lacking.” Recinto v. U.S. Dep’t of Veterans Affs., 706 14 F.3d 1171, 1175 (9th Cir. 2013). In contrast, claims of medical negligence “would not ‘possibly 15 have any effect on the benefits [a plaintiff] has already been awarded’” and can be brought in this 16 court. See Veterans for Common Sense, 678 F.3d at 1023 (quoting Littlejohn v. United States, 321 17 F.3d 915, 921 (9th Cir. 2003)); see also Tunac v. United States, 897 F.3d 1197, 1205–06 (9th Cir. 18 2018). 19 2. The Court does not have jurisdiction over Claim One.

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