Office of Personnel Management v. Richmond

Background

A disabled federal worker who had retired on disability sought advice about how much he could earn without losing his annuity. A Navy personnel specialist and an outdated Office of Personnel Management (OPM) form told him the older two-year earnings rule applied. Relying on that advice, he earned extra pay in 1986, exceeded the updated one-year limit, and lost six months of disability pay (about $3,993). He appealed through the Merit Systems Protection Board and the Federal Circuit, which ordered payment; the Government asked the Supreme Court to review.

Reasoning

The Court addressed whether incorrect oral or written advice from government employees can estop (prevent) the Government from refusing payment when a statute bars it. The Justices held that money cannot be paid from the federal Treasury unless Congress has authorized the payment by law. Relying on the Constitution’s Appropriations Clause and past decisions, the Court ruled that courts may not order payments that conflict with statutory limits and reversed the Court of Appeals. The Court left open whether estoppel might ever apply in other, non-monetary contexts.

Real world impact

The ruling means people who rely on agency mistakes generally cannot force payment from federal funds if the statute forbids it. Those hurt by bad advice must ask Congress or rely on specific statutory relief rather than expect courts to create new payment rights. Agencies may face fewer judicially imposed monetary liabilities for misinformation, though Congress can still pass laws to remedy particular hardships.

Dissents or concurrances

Justices wrote separately: one concurred but noted limits; another agreed with the result but disagreed about using the Appropriations Clause; a dissent argued the equities favored the claimant and that estoppel should apply.