Vowels v. United States

CourtCourt of Appeals for the Federal Circuit
DecidedApril 16, 2026
Docket25-1606
StatusUnpublished

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

Bluebook
Vowels v. United States, (Fed. Cir. 2026).

Opinion

Case: 25-1606 Document: 60 Page: 1 Filed: 04/16/2026

NOTE: This disposition is nonprecedential.

United States Court of Appeals for the Federal Circuit ______________________

LESLEY VOWELS, Plaintiff-Appellant

v.

UNITED STATES, Defendant-Appellee ______________________

2025-1606 ______________________

Appeal from the United States Court of Federal Claims in No. 1:25-cv-00064-RMM, Judge Robin M. Meriweather. ______________________

Decided: April 16, 2026 ______________________

LESLEY VOWELS, Louisville, KY, pro se.

ELINOR JOUNG KIM, Commercial Litigation Branch, Civil Division, United States Department of Justice, Wash- ington, DC, for defendant-appellee. Also represented by ERIC P. BRUSKIN, PATRICIA M. MCCARTHY, BRETT SHUMATE. ______________________

Before MOORE, Chief Judge, MAYER and LOURIE, Circuit Judges. Case: 25-1606 Document: 60 Page: 2 Filed: 04/16/2026

PER CURIAM. Lesley Vowels appeals the United States Court of Fed- eral Claims dismissal of her complaint for failure to prose- cute. For the following reasons, we affirm. BACKGROUND On January 13, 2025, Ms. Vowels filed a complaint against the United States in the Court of Federal Claims seeking redress for an alleged violation of her constitu- tional and statutory rights by federal and state officials. S. Appx. 15–24.1 Ms. Vowels’ claim primarily relates to a state-court-ordered eviction and repossession of two vehi- cles, which she asserts violated her rights as a person with disabilities. See id. She also claims Kentucky state courts, the United States District Court for the Western District of Kentucky, and the United States Court of Appeals for the Sixth Circuit have denied her access to the courts after dis- missing at least twenty-eight other cases and appeals.2 Id. at 18–19, 21–22. Ms. Vowels’ complaint seeks redress un- der the Federal Tort Claims Act, the Fifth and Fourteenth Amendments, and the Americans with Disabilities Act (ADA). Id. at 19–20. Ms. Vowels’ filings with the Court of Federal Claims failed to comply with the court’s rules on multiple occa- sions, including for lack of a signature and a valid mailing address. After the Court of Federal Claims issued four

1 “S. Appx.” refers to the Supplemental Appendix at- tached to the Government’s Brief. 2 Ms. Vowels raises several other issues in her brief, including a constitutional challenge to state legislation, de- nial of her right to trial by jury, and abuse of power for lack of judicial recusal. Appellant’s Br. at 6, 10–12. Those alle- gations, however, are not relevant to the Court of Federal Claims dismissal of this case for Ms. Vowels’ failure to prosecute, and we do not address them here. Case: 25-1606 Document: 60 Page: 3 Filed: 04/16/2026

VOWELS v. US 3

orders providing Ms. Vowels an opportunity to comply with the court’s rules, the court dismissed her complaint for fail- ure to prosecute under Rule 41(b). S. Appx. 1–3. Ms. Vow- els appeals.3 We have jurisdiction under 28 U.S.C. § 1295(a)(3).4 DISCUSSION We review the Court of Federal Claims dismissal of a complaint under Rule 41(b) for an abuse of discretion. Ka- din Corp. v. United States, 782 F.2d 175, 176 (Fed. Cir. 1986) (citations omitted). A pro se litigant is afforded leni- ency on procedural matters, but that leniency “does not translate to unfettered deference and dereliction of judicial review.” Steffen v. United States, 995 F.3d 1377, 1380 (Fed. Cir. 2021). The Court of Federal Claims dismissed Ms. Vowels’ complaint for her “failure to comply with the Court’s Or- ders, and . . . the Court’s inability to contact Ms. Vowels be- cause she has failed to either provide a valid mailing

3 On April 2, 2026, Ms. Vowels submitted a motion seeking relief in the form of a criminal investigation into actions taken by state and federal actors that she alleges resulted in a gun shot wound. Dkt. No. 58 at 6–7, 11. This is a court of limited jurisdiction, which does not include ju- risdiction over criminal matters. 28 U.S.C. § 1295. Accord- ingly, we deny Ms. Vowels’ motion. 4 Although the Court of Federal Claims dismissed Ms. Vowel’s complaint without reaching the question of ju- risdiction, we find that at least her Fifth Amendment claim meets the minimal showing required for the Court of Fed- eral Claims to exercise jurisdiction. See Columbus Reg’l Hosp. v. United States, 990 F.3d 1330, 1341 (Fed. Cir. 2021) (citing Lewis v. United States, 70 F.3d 597, 602 (Fed. Cir. 1995)) (citations omitted); 28 U.S.C. § 1491(a). The Gov- ernment does not contest jurisdiction. Case: 25-1606 Document: 60 Page: 4 Filed: 04/16/2026

address or consent to electronic notification.” S. Appx. 2. Specifically, the court cited Ms. Vowels’ failure to comply with the court’s January 31, 2025 order instructing Ms. Vowels to “(1) file a corrected, signed Complaint pur- suant to RCFC 5.5(d)(1)(A)(i) and 11(a); (2) at that time, provide either a valid mailing address or consent to elec- tronic notification, so that the Court may have a legally valid means of contacting her; and (3) file an application to proceed [in forma pauperis] that uses [the Court of Federal Claims’] form or pay the required fees on or before Febru- ary 21, 2025.” Id. at 1 (citing S. Appx. 13–14). Yet Ms. Vowels “repeatedly and without valid justification ig- nored both court-imposed deadlines and court rules,” and failed to submit any responsive filings. Kadin, 782 F.2d at 176–77. We see no abuse of discretion with the Court of Federal Claims dismissal under these circumstances. Regarding the court’s request for a signed complaint and contact in- formation, the rules are unambiguous. “The court must strike an unsigned paper unless the omission is promptly corrected after being called to the attorney’s or party’s at- tention.” RCFC 11(a) (emphasis added). Additionally, “[e]very pleading, written motion, and other pa- per . . . must state the signer’s address, e-mail address, and telephone number.” Id. (emphasis added). The court un- ambiguously set February 21, 2025, as the deadline for compliance, S. Appx. 14; warned that failure to comply may lead to dismissal without prejudice, id.; and reminded Ms. Vowels on three separate occasions of her obligation to comply, S. Appx. 10, S. Appx. 11, S. Appx. 12. Ms. Vowels’ continued and unexplained failure to comply despite these repeated reminders was ample justification for the court to dismiss Ms. Vowels’ complaint for failure to prosecute. Ms. Vowels makes several arguments about the merits of her case on appeal, but virtually none addresses the Court of Federal Claims’ stated rationale for dismissal— namely, Ms. Vowels’ failure to comply with the court’s rules Case: 25-1606 Document: 60 Page: 5 Filed: 04/16/2026

VOWELS v. US 5

and orders. At best, Ms. Vowels appears to argue that mail fraud and a subsequent investigation prevented her from receiving mail beginning at least shortly before she filed her complaint. See Appellant’s Br. at 5, 17. But even if Ms. Vowels’ mail fraud statements are construed to mean she never received the court’s orders, her allegation of mail fraud does not excuse non-compliance. Ms. Vowels was not required to receive notice prior to dismissal. See Claude E. Atkins Enters., Inc. v.

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Link v. Wabash Railroad
370 U.S. 626 (Supreme Court, 1962)
Kadin Corporation v. The United States
782 F.2d 175 (Federal Circuit, 1986)
Claude E. Atkins Enterprises, Inc. v. The United States
899 F.2d 1180 (Federal Circuit, 1990)
James L. Lewis v. United States
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995 F.3d 1377 (Federal Circuit, 2021)

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