Sequence of events is not a legal claim

In the adjudicated case of Peter David Schiff v. IRS, Mr. Schiff presented a theory.

The IRS investigated him. Euro Pacific International Bank, a financial institution he owned, collapsed. A $17.5 million stock sale to Qenta fell through. Puerto Rico regulators, who initially supported the sale, had a change of heart. And a reporter received information that could only have come from an official source. The sequence appeared coordinated, so he concluded there was coordination.

Then he sued.

The Court dismissed the case, stating that a sequence of events does not constitute a legal claim.

This point deserves emphasis. The complaint alleged that IRS investigators pressured Puerto Rico regulators, leaked damaging information, and coordinated efforts to bring down the bank. The Court did not find evidence that these actions occurred. Instead, it determined that the complaint failed to connect these events to specific unlawful acts by named officials within a legal framework that would permit the claim.

Courts do not evaluate sequences of events; they evaluate individual acts. A Court will not infer additional actions based on a pattern. Instead, it examines each event separately, determines whether a named individual committed a legally prohibited act, and assesses whether a statute allows the claim to proceed. If any step fails, the case is dismissed.

The plaintiff’s overall experience is never the focus of the legal inquiry. This is not a flaw in the system; it is how the system is designed to function.

The Federal Tort Claims Act requires plaintiffs to file an administrative claim before proceeding to Court. Failure to complete this step results in dismissal, regardless of the case’s merits. This exhaustion requirement exists because Congress determined that the government should address grievances internally before subjecting them to judicial review. Courts treat this as a jurisdictional issue, and a sense of harm does not override it.

Sovereign immunity operates similarly. The United States may be sued only when Congress has explicitly authorized it. As a result, a plaintiff may experience genuine financial harm from government action but still have no legal recourse if statutory permission for that claim does not exist. The government defines the terms of its own accountability, and those terms are intentionally narrow.

Individual officials receive similar protections. Constitutional claims against federal officers require that the complaint name the officer and specify the officer's actions. General allegations of coordination, pressure, or indirect influence are insufficient. The doctrine does not consider whether the plaintiff’s theory is plausible in common sense terms; it requires concrete facts about identifiable conduct by specific individuals.

Modern enforcement involves multiple agencies. Tax investigators, banking regulators, prosecutors, and international counterparts may all focus on the same target simultaneously. In such situations, decisions that should be independent can appear coordinated. This impression is understandable, as agencies communicate and share information. Whether such communication crossed a legal boundary is a legitimate question.

However, the legal system does not evaluate cases by examining patterns and inferring actions. It requires a specific, named act connected to a statute that permits the claim.

Anything less is considered circumstantial and does not meet the legal standard.

A legal system that treated patterns as evidence of wrongdoing would function differently. It would expose the government to lawsuits based on timing and suspicion. Courts have deliberately chosen not to operate this way, and their reasons are well established and reasonable.

This approach produces a consistent result. Individuals who perceive enforcement as a coordinated campaign often describe more than the law will acknowledge. This is not because their account is inaccurate, but because the law addresses a different question than the one they are asking.

This gap will persist, and describing it as accidental would be incorrect.