The U.S. Court of Appeals for the Federal Circuit affirmed the dismissal of a pro se plaintiff's challenge to Russian sanctions in *Tindall v. United States*, issued January 8, 2026. The nonprecedential decision upheld the Court of Federal Claims' dismissal of James Tindall's complaint for failure to state a claim on res judicata grounds.
Tindall, a Georgia resident representing himself, owns shares in a Russian-majority state-owned bank that became subject to U.S. sanctions following Russia's actions against Ukraine. The case stems from Executive Order No. 14,024, issued by then-President Biden in 2021, which blocked property related to specified harmful foreign activities of the Russian Federation.
The executive order led to concrete action in February 2022, when the Office of Foreign Assets Control (OFAC) of the U.S. Department of Treasury issued sanctions prohibiting the processing of securities transactions involving certain Russian financial institutions. These sanctions directly affected Tindall's shareholdings in the targeted bank, effectively blocking his ability to conduct transactions involving his shares.
Tindall filed suit in the Court of Federal Claims seeking relief from the sanctions' impact on his financial interests. However, the lower court dismissed his complaint, finding that res judicata barred his claims. Res judicata, also known as claim preclusion, prevents parties from relitigating claims that have already been decided in previous cases.
The dismissal on res judicata grounds suggests that Tindall may have previously brought similar claims against the government regarding the same sanctions or related matters. Courts apply this doctrine to prevent endless relitigation of the same disputes and to provide finality to judicial decisions.
On appeal to the Federal Circuit, a three-judge panel consisting of Circuit Judges Lourie, Taranto, and Chen reviewed the lower court's decision. Judge Lourie authored the opinion affirming the Claims Court's dismissal. The Federal Circuit found no error in the lower court's application of res judicata principles to Tindall's case.
The case highlights the challenges facing individual investors whose assets became entangled in the broad sanctions regime imposed on Russia following its 2022 invasion of Ukraine. The Biden administration's sanctions targeted Russian financial institutions as part of a coordinated international response to Russia's military actions.
Tindall represented himself throughout the proceedings, while the Department of Justice's Commercial Litigation Branch defended the government's position. The DOJ team included attorneys Bryan Michael Byrd, Elizabeth Marie Hosford, Patricia M. McCarthy, and Brett Shumate.
The Federal Circuit's decision is designated as nonprecedential, meaning it cannot be cited as binding authority in future cases. Such dispositions typically involve straightforward applications of established legal principles rather than novel questions of law.
The sanctions program that affected Tindall's investments represents part of the most comprehensive economic restrictions the U.S. has ever imposed on a major economy. The measures targeted Russian banks, state-owned enterprises, and other entities to pressure Russia economically while limiting its ability to finance military operations.
For individual investors like Tindall who held stakes in Russian entities before the sanctions took effect, the restrictions created significant financial hardships. However, courts have generally upheld the government's broad authority to impose sanctions for national security purposes, even when they affect innocent third parties.
The res judicata dismissal suggests that Tindall's legal challenges to the sanctions regime have reached their end, at least through this particular avenue. The doctrine serves as a powerful tool for courts to manage their dockets and prevent the same disputes from consuming judicial resources repeatedly.
The timing of the Federal Circuit's decision, coming nearly two years after the initial sanctions took effect, reflects the complex litigation surrounding the Russia sanctions program. Many affected parties have sought relief through various legal channels, though courts have generally deferred to executive branch authority in matters of foreign policy and national security.
This case illustrates the intersection of foreign policy, economic sanctions, and individual property rights. While the sanctions serve broader geopolitical objectives, they inevitably create winners and losers among private parties, including American investors who may have had legitimate business interests in targeted countries.
The Federal Circuit's affirmance reinforces the finality principle underlying res judicata doctrine and demonstrates the courts' reluctance to second-guess executive branch decisions on sanctions policy. For future litigants challenging sanctions programs, the decision serves as a reminder of the procedural hurdles that can bar substantive review of their claims.