holding that pro se complaints should be held “to less stringent standards than formal pleadings drafted by lawyers”
How later courts described this case
- holding that pro se complaints should be held “to less stringent standards than formal pleadings drafted by lawyers”
Written by the judges who cited it.
The opinion
In the United States Court of Federal Claims
)
CHRISTOPHER WILLIAMS, )
)
Plaintiff, )
) No. 25-2064
v. ) (Filed: March 25, 2026)
)
THE UNITED STATES, )
)
Defendant. )
)
Christopher Williams, pro se, Salters, SC.
Corinne A. Niosi, U.S. Department of Justice, Washington, DC, with whom were Patricia M.
McCarthy and Brett A. Shumate, for Defendant.
OPINION AND ORDER
KAPLAN, Judge.
Before the Court is pro se Plaintiff Christopher Williams’ Motion to Correct Complaint.
Mot. to Correct Compl., Dkt. No. 12. 1 This Motion comes after the Court sua sponte dismissed
Mr. Williams’ Complaint for lack of subject-matter jurisdiction pursuant to RCFC 12(h)(3). Op.,
Dkt. No. 9; Williams v. United States, No. 25-2064, 2026 WL 64092 (Fed. Cl. Jan. 8, 2026). The
Court dismissed Mr. Williams’ Complaint because the United States Court of Federal Claims
lacks jurisdiction over claims alleging violations of civil rights brought under 42 U.S.C. § 1983.
Williams, 2026 WL 64092, at *2 (citing Elkins v. United States, 229 Ct. Cl. 607, 608 (1981)).
In the present motion, Mr. Williams now claims he mistakenly brought his claim under
§ 1983 and his Complaint should have been construed as a Bivens claim. Mot. to Correct Compl.
at 1–2; see also Bivens v. Six Unknown Named Agents of Fed. Bureau of Narcotics, 403 U.S.
388 (1971). At this stage, RCFC 15(a)(2) allows a party to amend its own pleading “only with
the opposing party’s written consent or the court’s leave” and provides that “[t]he court should
freely give leave when justice so requires.” Factors that may justify the denial of a motion to
amend pleadings include “undue delay, bad faith or dilatory motive on the part of the movant,
repeated failure to cure deficiencies by amendments previously allowed, undue prejudice to the
opposing party by virtue of allowance of the amendment, [or] futility of amendment.” Mitsui
Foods, Inc. v. United States, 867 F.2d 1401, 1403–04 (Fed. Cir. 1989) (alteration in original)
1
Mr. Williams filed what appears to be the same motion twice. Compare Mot. to Correct
Compl., Dkt. No. 12, with Mot. to Correct Compl., Dkt. No. 13. Because the motions are
identical, the Court discusses them as if Mr. Williams filed only one motion.
(quoting Foman v. Davis, 371 U.S. 178, 182 (1962)). “The existence of any one of these criteria
is sufficient to deny a motion to amend, the theory being that the amendment would not be
necessary to serve the interests of justice under such circumstances.” Spalding & Son, Inc. v.
United States, 22 Cl. Ct. 678, 680 (1991).
Mr. Williams’ Motion to Correct Complaint is futile because it would not cure the
Complaint’s jurisdictional defect. See Kemin Foods, L.C. v. Pigmentos Vegetales Del Centro
S.A. de C.V., 464 F.3d 1339, 1354–55 (Fed. Cir. 2006) (finding a motion to amend futile
because the amended pleading could not “survive a dispositive pretrial motion”). As with § 1983
claims, the United States Court of Federal Claims lacks subject-matter jurisdiction over Bivens
suits. Brown v. United States, 105 F.3d 621, 624 (Fed. Cir. 1997). For that reason, the Motion to
Correct Complaint must be denied.
Alternatively, the instant motion could be construed as either a motion for
reconsideration or a motion for relief from judgment. In his motion, Mr. Williams cited Rule
58(d)—which provides that “[a] party may request that judgment be set out in a separate
document” and apparently does not apply to the instant motion—but may have intended to cite
RCFC 59(a)(a) or RCFC 60(b). Mot. to Correct Compl. at 2; see also Haines v. Kerner, 404 U.S.
519, 521 (1972) (holding that pro se complaints should be held “to less stringent standards than
formal pleadings drafted by lawyers”). Under RCFC 59(a)(1), motions for reconsideration may
be granted “when there has been an intervening change in the controlling law, newly discovered
evidence, or a need to correct clear factual or legal error or prevent manifest injustice.” Biery v.
United States, 818 F.3d 704, 711 (Fed. Cir. 2016) (quoting Young v. United States, 94 Fed. Cl.
671, 674 (2010)). Under RCFC 60(b), relief may be granted for any of six enumerated reasons:
(1) mistake, inadvertence, surprise, or excusable neglect;
(2) newly discovered evidence that, with reasonable diligence, could not have been
discovered in time to move for a new trial under RCFC 59(b);
(3) fraud (whether previously called intrinsic or extrinsic), misrepresentation, or
misconduct by an opposing party;
(4) the judgment is void;
(5) the judgment has been satisfied, released, or discharged; it is based on an earlier
judgment that has been reversed or vacated; or applying it prospectively is no longer
equitable; or
(6) any other reason that justifies relief.
Motions brought under these rules must be supported by a showing of “extraordinary
circumstances.” Caldwell v. United States, 391 F.3d 1226, 1235 (Fed. Cir. 2004) (quoting Fru-
Con Constr. Corp. v. United States, 44 Fed. Cl. 298, 300 (1999)) (discussing RCFC 59(a)); Perry
v. United States, 558 Fed. App’x 1004, 1006 (Fed. Cir. 2014) (quoting Liljeberg v. Health Servs.
Acquisition Corp., 486 U.S. 847, 864 (1988)) (discussing (RCFC 60(b)).
2
None of the grounds for relief or reconsideration are met here. It is well settled and
beyond dispute that this court lacks subject-matter jurisdiction over both § 1983 claims and
Bivens suits. There has been no change in the law, newly discovered evidence, or clear legal
error that merits vacating the dismissal of Mr. Williams’ claim. Nor has Mr. Williams
demonstrated extraordinary circumstances that justify relief.
For the foregoing reasons, Mr. Williams’ Motion to Correct Complaint, Dkt. Nos. 12, 13,
is DENIED.
IT IS SO ORDERED.
ELAINE D. KAPLAN
Judge
3