“[A] claim is subject to the Tucker Act and its jurisdictional consequences if, in whole or in part, it explicitly or ‘in essence’ seeks more than $10,000 in monetary relief from the federal government.”
How later courts described this case
- “[A] claim is subject to the Tucker Act and its jurisdictional consequences if, in whole or in part, it explicitly or ‘in essence’ seeks more than $10,000 in monetary relief from the federal government.”
Written by the judges who cited it.
The opinion
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
MARVIN KNIGHT, )
)
Plaintiff, )
)
v. ) Civil Action No. 1:25-cv-03749 (UNA)
)
IRS, et al., )
)
Defendants. )
MEMORANDUM OPINION
This matter is before the Court on its initial review of Plaintiff’s pro se Complaint
(“Compl.”), ECF No. 1, and Application for Leave to Proceed in forma pauperis (“IFP”), ECF No.
2. The Court grants Plaintiff’s IFP Application, and for the reasons discussed below, it dismisses
the Complaint, and this matter, without prejudice.
Plaintiff, a resident of the District of Columbia, sues the Internal Revenue Service and the
D.C. Office of Tax and Revenue. See Compl. at 1–4. The Complaint is vague and difficult to
understand. Plaintiff broadly alleges only that he is “seeking damages for improper IRS actions
unauthorized collection and disclosure. Unauthorize[d] inspection and disclos[ure] by an[] IRS
officer or employees in the [D]istrict of [C]olumbia. Yes the IRS processed my amended tax
refund.” See id. at 4. He again similarly and ambiguously states that the IRS did not issue his
“taxes, [his] amended taxes, improper garnishment, damages.” See id. The specific involvement
of the D.C. Office of Tax and Revenue, if any, is not clearly stated.
First, Federal Rule 8(a) requires complaints to contain “(1) a short and plain statement of
the grounds for the court’s jurisdiction [and] (2) a short and plain statement of the claim showing
that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a); see Ashcroft v. Iqbal, 556 U.S. 662, 678-
79 (2009); Ciralsky v. CIA, 355 F.3d 661, 668–71 (D.C. Cir. 2004). The Rule 8 standard ensures
that defendants receive fair notice of the claim being asserted so that they can prepare a responsive
answer and an adequate defense and determine whether the doctrine of res judicata applies. Brown
v. Califano, 75 F.R.D. 497, 498 (D.D.C. 1977). Notably, “[a] confused and rambling narrative of
charges and conclusions . . . does not comply with the requirements of Rule 8.” Cheeks v. Fort
Myer Constr. Corp., 71 F. Supp. 3d 163, 169 (D.D.C. 2014) (citation and internal quotation marks
omitted). The instant Complaint falls within this category. Little to no context or supporting
details are provided. It is unclear how, when, why, or what specific wrongdoing either Defendant
allegedly committed, and as pleaded, neither Court nor Defendants have adequate notice of a
cognizable claim, nor has Plaintiff established his entitlement to relief, if any.
Insofar as Plaintiff may, perhaps, seek a refund or otherwise recover monies from the IRS,
this Court lacks subject matter jurisdiction. As background, the district courts shall generally have
original jurisdiction concurrent with the United States Court of Federal Claims over tax refund
claims. See 28 U.S.C. § 1346(a)(1); see also 26 U.S.C. § 7422. However, the Tucker and Little
Tucker Acts, 28 U.S.C. §§ 1491, 1346(a)(2), clarify the circumstances in which the United States
may be sued for monetary relief, and applicable here, the Court of Federal Claims generally bears
exclusive jurisdiction over claims “not sounding in tort” and brought “against the United States
for ‘liquidated or unliquidated damages’” exceeding $10,000. Smalls v. United States, 471 F.3d
186, 189 (D.C. Cir. 2006) (quoting 28 U.S.C. § 1491); see Kidwell v. Dep’t of Army, Bd. for
Correction of Military Records, 56 F.3d 279, 284 (D.C. Cir. 1995) (“[A] claim is subject to the
Tucker Act and its jurisdictional consequences if, in whole or in part, it explicitly or ‘in essence’
seeks more than $10,000 in monetary relief from the federal government.”) (citations omitted).
Here, assuming arguendo Plaintiff had stated a cogent legal claim, he has demanded in excess of
$75,000 in damages, see Compl. at 4; therefore, the U.S. Court of Federal Claims would bear
exclusive jurisdiction over this case, see 28 U.S.C. § 1346(a)(2).
Accordingly, this case is dismissed without prejudice. Plaintiff’s other pending Motions,
ECF Nos. 4, 5, 6, 7, 8, and 9, are all denied as moot. A separate Order accompanies this
Memorandum Opinion.
Date: January 2, 2026
/s/_________________________
ANA C. REYES
United States District Judge