Dieujuste V United States

Key Facts

Issues

• The Court must determine if it has subject-matter jurisdiction to hear a Fifth Amendment takings claim brought against the United States, where the claim arises from the alleged actions of state agents (New York family court officials) who issued orders using the plaintiff's trademarked name. The Court concludes that the federal government is not liable for the actions of state agents merely because they receive federal funding, and thus lacks jurisdiction over the claim.
• The Court addresses whether the plaintiff's assertion of a procedural due process violation under the Fifth Amendment, based on the government's refusal to license his name, constitutes a valid Tucker Act claim. The Court dismisses this claim, citing established precedent that the Due Process Clauses do not provide a cause of action for monetary relief under the Tucker Act.

Holdings

• Federal funding of state programs does not make state entities agents of the United States, thus not exposing the federal government to liability in this Court. The Court cites precedents holding that federal oversight or funding alone does not establish federal agency status.
• The remaining takings claim is dismissed for lack of subject-matter jurisdiction, as the state agents' actions (even with federal funding oversight) are not attributable to the federal government. The Court rejects plaintiff's argument that federal funding transforms state actors into federal ones.
• The procedural due process claim is dismissed as it fails to allege a cause of action under the Tucker Act. The Due Process Clauses do not mandate monetary payments, precluding recovery for the alleged refusal to license.
• The Court lacks subject-matter jurisdiction over claims against state agents, as jurisdiction is limited to claims against the United States. Absolute immunity protects judicial officers in their official capacity, and the Rooker-Feldman doctrine bars review of state court proceedings.

Remedies

• The Clerk of Court was directed to vacate the defendant's reply deadline following the dismissal of the case.
• The court dismissed the plaintiff's complaint due to lack of subject-matter jurisdiction over the claims.

Legal Principles

• The Rooker-Feldman doctrine was applied to bar Mr. Dieujuste's claims to the extent they sought review of state court judicial proceedings and determinations, as federal courts cannot act as appellate courts over state court decisions.
• The Court held that the United States is not liable for the actions of state officials, even if those officials receive federal funding, as the federal government is not an agent or employer of state agencies. This is grounded in the principle of Sovereign Immunity.
• The Domestic-Relations Abstention Doctrine required the district court to abstain from exercising its federal question jurisdiction over the matrimonial matter of child support, as such matters are typically handled by state courts.

Precedent Name

• Malone v. United States
• Duncan v. United States
• Chisum v. United States
• Hitsman v. United States
• Dicrescenzo v. United States
• Polinski v. United States
• Bram v. United States

Cited Statute

Judge Name

Passage Text

• Dismissing the action for lack of subject-matter jurisdiction, the district court explained: the two state court officials were 'entitled to absolute immunity in their capacity as judicial officers'; the Domestic-Relations Abstention Doctrine required the district court 'to abstain from exercising its federal question jurisdiction over squarely matrimonial matters'; and 'the Rooker-Feldman doctrine bar[red] [Mr. Dieujuste]'s claims to the extent that he sought review of state court judicial proceedings and determinations.'
• Accordingly, Mr. Dieujuste's remaining claim must be dismissed for lack of subject-matter jurisdiction.
• A state agency's receipt of federal funding does not expose the federal government to potential liability in this Court for the state agency's allegedly unlawful actions. See Polinski v. United States, No. 24-1810, 2025 WL 635638, at *1 (Fed. Cl. Feb. 26, 2025) ('...Even if the federal government is funding [a state entity], that is not sufficient to make the United States liable for the alleged actions of the [state entity].'), aff'd, No. 25-1578, 2025 WL 1441953 (Fed. Cir. May 20, 2025), cert. denied, __ S. Ct. __, No. 25-6298, 2026 WL 135698 (U.S. Jan. 20, 2026) (mem.); Bram v. United States, 102 Fed. Cl. 752, 754 (2012) ('Receipt of federal funds does not make an entity an agent of the United States.')