United States v. Sherwood
312 U.S. 584 (1941)
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Rule of Law:
The jurisdiction of a United States District Court under the Tucker Act is strictly concurrent with that of the Court of Claims. Therefore, a district court cannot entertain a suit against the United States if it involves adjudicating the rights of private third parties, as such a suit would be beyond the jurisdiction of the Court of Claims.
Facts:
- The United States entered into a contract with a man named Kaiser for the construction of a post office building.
- The United States allegedly breached this contract, resulting in damages to Kaiser.
- A man named Sherwood obtained a judgment for $5,567.22 against Kaiser in the New York Supreme Court.
- Under the authority of a New York state law, the New York Supreme Court issued an order permitting Sherwood, as Kaiser's judgment creditor, to sue the United States to recover on the government's alleged debt to Kaiser.
Procedural Posture:
- Sherwood sued the United States and Kaiser in the U.S. District Court for the Eastern District of New York.
- The District Court, a court of first instance, dismissed the complaint for want of jurisdiction.
- Sherwood, as appellant, appealed to the U.S. Court of Appeals for the Second Circuit, an intermediate appellate court.
- The Court of Appeals reversed the District Court's dismissal, holding that the suit could proceed.
- The United States, as petitioner, sought and was granted a writ of certiorari by the U.S. Supreme Court to review the decision of the Court of Appeals.
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Issue:
Does a United States District Court have jurisdiction under the Tucker Act to entertain a suit against the United States brought by a judgment creditor, when the suit also requires the adjudication of rights between the creditor and the original judgment debtor?
Opinions:
Majority - Mr. Justice Stone
No. The jurisdiction conferred on district courts by the Tucker Act is strictly limited to that which could be exercised by the Court of Claims, and does not extend to suits requiring the adjudication of rights between private parties. The United States, as a sovereign, is immune from suit except as it consents to be sued, and any waiver of this immunity must be strictly construed. The Tucker Act provides such a waiver for certain contract claims, granting district courts jurisdiction that is 'concurrent with the Court of Claims.' The Court of Claims' jurisdiction is limited to rendering money judgments in suits brought solely against the United States and does not extend to adjudicating disputes between private litigants. This suit, brought by Sherwood, necessarily involves resolving the rights between Sherwood and the judgment debtor, Kaiser, which is beyond the scope of the Court of Claims' authority. Therefore, the district court also lacks jurisdiction. The Federal Rules of Civil Procedure, which govern court process, cannot expand the substantive jurisdiction of the federal courts or override the conditional nature of the government's waiver of sovereign immunity.
Analysis:
This case firmly establishes that the jurisdiction of federal district courts under the Tucker Act is precisely co-extensive with that of the Court of Claims, reinforcing the principle of strict construction for waivers of sovereign immunity. The decision clarifies that procedural mechanisms like the Federal Rules of Civil Procedure cannot be used to enlarge the substantive jurisdiction of federal courts to hear claims against the government. This precedent significantly limits the ability of third parties, such as creditors or assignees, to sue the government if their claim requires the court to resolve an ancillary dispute between private individuals, thereby shielding the U.S. from complex, multi-party litigation to which it has not explicitly consented.
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