United States v. Slaymaker

Background

Slaymaker, a naval reservist who enrolled during the War with Germany, received a $150 uniform gratuity when he first went on active duty as an officer. He was later commissioned into the regular Navy, and that $150 was charged against his regular-Navy pay, prompting him to sue to recover the money. The Court of Claims ruled for Slaymaker, and the Government appealed. The dispute turned on an 1916 law that gave uniform gratuities and said the credit must be deducted from money due a reservist who 'severs his connection with the service' without government compulsion.

Reasoning

The key question was what 'service' meant in the deduction clause and whether moving into the regular Navy counted as severing that connection. The Court read 'service' broadly to include continued service in the Naval Service even after promotion or transfer, reasoning that the gratuity was meant to attract and reward useful members and should not be treated as a penalty when they remained in government service. The Court noted a 1918 law that later barred deductions when reservists accepted temporary Navy appointments, but rested its decision on its interpretation of the 1916 act. The Supreme Court affirmed the Court of Claims judgment, so Slaymaker prevailed.

Real world impact

This decision prevents the Government from taking back the uniform gratuity in similar cases where a reservist accepts regular Navy service rather than truly leaving. It clarifies that such gratuities reward continued service and are not a chargeable debt when members move into other Navy roles. The ruling governs these facts and may guide how the Navy treats like cases.