Henderson v. Dept. of Veterans Affairs

Background

Terence Henderson, who was proceeding without a lawyer, sued the “Department of Veterans Affairs,” which the court understood to mean the United States Department of Veterans Affairs. He invoked federal-question jurisdiction and alleged that the agency refused to release funds that Congress had earmarked for disabled Cold War veterans. He also alleged that funds or entitlements had been delayed or misused and claimed back pay connected to events beginning in 1988.

Henderson filed the action using a court-issued employment-discrimination complaint form. Although he provided information about his race and disability, the court concluded that the apparent subject of the case was his entitlement to veterans’ benefits.

Jurisdictional ruling

The court applied the screening rules for complaints filed by people who are allowed to proceed without prepaying filing fees. Those rules require dismissal of a complaint that is frivolous, malicious, fails to state a legally sufficient claim, seeks money from an immune defendant, or falls outside the court’s subject-matter jurisdiction. The court also explained that it must dismiss a case when it lacks subject-matter jurisdiction, meaning the legal power to hear that type of dispute.

The court held that Henderson appeared to be challenging a decision about veterans’ benefits. The Veterans’ Judicial Review Act created a specific review process: a benefits decision by the Secretary of Veterans Affairs may be appealed to the Board of Veterans’ Appeals, then to the United States Court of Appeals for Veterans Claims, and then to the United States Court of Appeals for the Federal Circuit. According to the court, this structure excludes federal district courts from reviewing disputes involving the provision of veterans’ benefits.

The court therefore dismissed Henderson’s claims without prejudice for lack of subject-matter jurisdiction. The court did not reach the merits of whether Henderson was entitled to the claimed funds or benefits.

Other rulings and disposition

The court denied leave to amend, meaning permission to file an amended complaint in this action, because it concluded that an amendment could not cure the jurisdictional defect.

The court dismissed the action for lack of subject-matter jurisdiction, certified that any appeal would not be taken in good faith, denied Henderson permission to proceed without prepaying fees for purposes of an appeal, and directed the Clerk of Court to enter judgment.