Overlapping government lawsuits
United States v. Tohono O'odham Nation
In brief
The Supreme Court overturned the Federal Circuit and ruled that the shared facts kept the Court of Federal Claims from hearing the Nation’s suit.
- Where it stands
- Decided
Decided 7-1 · April 26, 2011 · Opinion by Justice Kennedy
- What it’s about
- The Tohono O’odham Nation sued the United States in two courts over trust assets, seeking different relief in each.
- Who it affects
- The Nation’s Court of Federal Claims suit cannot go forward because it substantially overlaps in facts with its separate District Court case.
Summary: written with AI from the case record.
What it's about
The Supreme Court decided federal law barred the Court of Federal Claims suit because both cases rested on substantially the same facts, overturned the Federal Circuit’s ruling, and sent the case back to that court (remanded).
A federal law limits when the Court of Federal Claims can hear a suit against the United States while another court is handling a case based on the same facts.
Question presented
A federal statute provides that the Court of Federal Claims lacks jurisdiction to hear a suit against the federal government raising a claim that is already being litigated against the government in another court. Does this provision apply when the plaintiff brings a lawsuit in both the Court of Federal Claims and another court based on the same set of facts, but seeks different forms of relief in the two cases?
What the Court decided
Holding
The substantial overlap in operative facts between the Nation’s District Court and CFC suits precludes jurisdiction in the CFC. Both actions allege that the United States holds the same assets in trust for the Nation’s benefit, and they describe almost identical breaches of fiduciary duty. 559 F. 3d 1284, reversed and remanded.
- Result
- Reversed
The Court's reasoning
The Court said the cases shared many key facts: both alleged that the United States held the same assets in trust for the Nation and described almost identical breaches of duty. It ruled that this overlap left the Court of Federal Claims without authority to hear the Nation’s suit.
The vote
- Joined the judgment
- Concurred in a separate opinion
- Dissented
- Wrote an opinion
- Concurring · 2agreed with the result, wrote separately
- Breyer
- Sotomayorwrote separately
- Dissenting · 1disagreed with the result
- Ginsburgwrote the dissent
From the opinions
“I dissent from the Court’s immoderate reading of 28 U. S. C. §1500 and would affirm the Federal Circuit’s judgment.”
What's next
The case returns to the Federal Circuit for further proceedings consistent with the Supreme Court’s ruling.
Documents
Opinions
Audio
Docket activity
New analysis added
AI analysis generated: Impact Analysis
AI analysis generated: Opinion Summary
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AI analysis generated: Case Briefing
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AI analysis generated: Decision Record
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Audio Recording added: Oral Arguments - United States v. Tohono O'odham Nation
Opinion added: Opinion
More questions
- Why did Justice Sotomayor say this case did not answer the different-relief question?
- She said the Nation sought some of the same relief in both cases, so the case did not test suits seeking only different forms of relief; the Court’s opinion still treated substantial factual overlap as enough to bar the Court of Federal Claims suit.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.