Summary of a Recent
Judicial Development in
Administrative Law

Court Has Jurisdiction Over Claims Arising
Out of Settlement Agreement

Amy Miller
National AgLaw Center Graduate Assistant

Hall v. United States, 69 Fed. Cl. 51 (Fed. Cl. 2005), the United States Court of Federal Claims considered whether it had jurisdiction to adjudicate claims arising out of a settlement agreement between the USDA and Mr. George W. Hall, a minority farmer ("Hall").

In 1997, Hall joined a class action suit alleging that because of racial bias the USDA failed to provide assistance to which he was entitled. Id. at 52. Hall subsequently entered into a settlement agreement with the USDA, then later filed suit in the United States District Court for the Northern District of Alabama alleging, among other things, that the agency breached the settlement agreement. Id. at 53. The District Court dismissed Hall's breach of the settlement claim but advised him the claim was subject to the Tucker Act, 28 U.S.C. § 1491(a)(1), and the jurisdiction of the United States Court of Federal Claims. Id. Hall subsequently filed a complaint in the Federal Claims court alleging he suffered substantial economic damages as well as undue hardship, emotional distress, mental anguish, humiliation, and harm to his good name and character. Id. at 53-54, 57.

The Federal Claims court noted that if the court's jurisdiction was solely dependent on violations of the Equal Credit Opportunity Act ("ECOA"), 15 U.S.C. §§ 1691, et seq., the claim would have been dismissed because the ECOA waiver only permitted a "loan applicant who [had] been treated in a discriminatory manner to bring an action in the United States district court." Id. at 56 (citation omitted). The court also noted that the Administrative Procedures Act ("APA"), 5 U.S.C.A. §§ 701 et seq., did not grant the United States Court of Federal Claims jurisdiction to review an agency decision because the APA addressed "relief other than money damages," and thus, claims filed on the basis of the APA must be filed in a federal district court. Id. (citation omitted).

However, the court held that the Tucker Act, 28 U.S.C. § 1491(a), provided an express waiver of sovereign immunity and granted the court jurisdiction to adjudicate Hall's breach of contract claims because the claim arose out of "an[] express . . . contract with the United States." Id. at 54.

Furthermore, the court concluded that it had jurisdiction to adjudicate tort claims that stem from a breach of contract, including emotional distress and pain and suffering, because "the cause of action [was] ultimately one arising in contract." Id. at 57 (citation omitted). Nevertheless, the court dismissed the portions of Hall's compliant that sought damages for emotional distress and pain and suffering because the Tucker Act did not provide the authority to award such damages. Id. at 58.

The case was decided on October 31, 2005; this summary was posted Feb. 21, 2006.