[JURIST] The US Supreme Court [official website; JURIST news archive] on Tuesday ruled [opinion, PDF] 7-1 in United States v. Tohono O'odham Indian Nation [Cornell LII backgrounder; JURIST report] that the tribe cannot bring a suit based on the same facts in both federal district court and the Court of Federal Claims (CFC) [official website]. 28 USC § 1500 [text] provides that the CFC lacks jurisdiction over "any claim for or in respect to which the plaintiff has any suit or process against the United States" or its agents "pending in any other court." The Tohono O'odham Nation filed a complaint against the US in the US District Court for the District of Columbia, and, one day later, it filed a similar complaint against the US in the CFC. The US Court of Appeals for the Federal Circuit reversed [opinion, PDF] the CFC's dismissal of the case, concluding "that the Nation's complaint in the Court of Federal Claims seeks relief that is different from the relief sought in its earlier-filed district court action." Reversing the decision below, Justice Anthony Kennedy wrote:
The two actions both allege that the United States holds the same assets in trust for the Nation's benefit. They describe almost identical breaches of fiduciary duty. ... Indeed, it appears that the Nation could have filed two identical complaints, save the caption and prayer for relief, without changing either suit in any significant respect.Justice Sonia Sotomayor filed an opinion concurring in the judgment, joined by Justice Stephen Breyer. Justice Ruth Bader Ginsburg filed a dissenting opinion. Justice Elena Kagan took no part in the decision.
Under §1500, the substantial overlap in operative facts between the Nation's District Court and CFC suits precludes jurisdiction in the CFC. The Court of Appeals erred when it concluded otherwise.
The tribe filed suit in federal district court alleging that the US government had breached its fiduciary duty by mismanaging funds held in trust for the tribe. The suit sought an accounting and other equitable relief. The tribe then filed suit in the CFC seeking monetary relief. The CFC dismissed the suit, finding that it lacked jurisdiction.