Sunday, October 27, 2013

Office of Personnel Management v. Richmond case brief

Office of Personnel Management v. Richmond case brief summary
496 U.S. 414 (1990)

Petitioner, the Office of Personnel Management, discontinued respondent claimant's disability annuity. The Merit Systems Protection Board denied his petition for review. He appealed to the United States Court of Appeals for the Federal Circuit, which applied estoppel against the government, entitling respondent to a monetary payment not otherwise permitted by law. Certiorari was granted.

Not wishing to exceed a statutory limit on earnings that would disqualify him from a disability annuity, respondent claimant sought advice from a federal employee and received erroneous information. As a result, he earned more than permitted by the eligibility requirements of the relevant statute and lost six months of benefits. Respondent contended that the erroneous and unauthorized advice should give rise to equitable estoppel against the government, and that the Court should order payment of the benefits contrary to the statutory terms.

  • The court held that payments of money from the federal Treasury were limited to those authorized by statute. 
  • The Appropriations Clause provided that no money could be paid out of the Treasury unless it had been appropriated by an act of Congress. 
  • All parties agreed that the award respondent sought would have been in direct contravention of the federal statute upon which his ultimate claim to the funds rested, 5 U.S.C.S. § 8337. 
  • Respondent pointed to no authority in precedent or history for the type of claim he advanced. 
  • The Court had never upheld an assertion of estoppel against the government by a claimant seeking public funds.
The United States Supreme Court reversed the judgment of the appellate court, holding that estoppel could not be applied to entitle respondent claimant to benefits.

Recommended Supplements for Administrative Law Examples & Explanations: Administrative Law, Fourth Edition
Administrative Law and Process: In a Nutshell (Nutshell Series)

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