Office of Personnel Management v. Richmond

In Office of Personnel Management v. Richmond, 496 U.S. 414 (1990), the respondent, a federal employee, left his position after his application for disability retirement was approved. 496 U.S. at 416. After receiving erroneous information from the Office of Personnel Management, the respondent obtained part-time work and earned an annual wage that exceeded the statutory maximum for disability retirement. Id. at 417. As a result, the respondent's disability retirement was discontinued. Id. The respondent appealed the decision to discontinue his retirement benefits, arguing that the government's misinformation was grounds for estoppel. Id. at 418-19. The government countered that estoppel could not nullify the statutory maximum prescribed by Congress. Id. On review, the United States Supreme Court ("U.S. Supreme Court") cited to the Appropriations Clause and its "straightforward and explicit command" that no money can be paid out of the Federal Treasury unless it is appropriated by an act of Congress. Id. at 424. Because the award sought by the respondent would be in "direct contravention" of a federal statute, the U.S. Supreme Court reasoned that the award would violate the Appropriations Clause by paying out money not appropriated by Congress. Id. at 424-26. It accordingly rejected the respondent's estoppel argument and concluded that he was not entitled to a re-instatement of his disability benefits, despite the fact that he lost the benefits as a result of the government's own mistake. Id.