Richardson v. Morris

Background

Appellees are children born out of wedlock who brought a class action seeking to block enforcement of §203(a) of the Social Security Act. The District Court granted declaratory and injunctive relief, relying on the Tucker Act as the basis for its jurisdiction. The parties disputed whether the children could challenge the statute’s facial constitutionality without first using administrative remedies provided under the Social Security Act.

Reasoning

The main question was whether the district court properly used the Tucker Act to hear a suit seeking equitable relief against the United States. The Court explained that the Tucker Act gives district courts concurrent jurisdiction with the Court of Claims for certain claims for money damages under $10,000, but has long been read to allow only money judgments and not injunctions or other equitable relief against the Government. (The Tucker Act is a federal statute that normally covers money claims against the United States.) Because the District Court treated the case as an action for equitable relief under that Act, the Court found that approach was incorrect. The Court did not decide the constitutional challenge to §203(a).

Real world impact

The judgment granting relief is vacated and the case is sent back for further proceedings so the District Court can consider proper jurisdictional grounds. The underlying constitutional question remains unresolved and may be revisited if the lower court finds another valid basis to proceed. The Court also granted the plaintiffs leave to proceed in forma pauperis.