United States v. Edmondston

Background

A private buyer paid $2.50 per acre (totaling $400) for a tract of public land, although an 1880 law reduced that land’s price to $1.25 per acre. The purchaser later sued in the Court of Claims to recover the alleged overpayment. The lower court had allowed recovery, and the case reached the Supreme Court for decision.

Reasoning

The Court addressed whether a payment to the government made without objection is voluntary and therefore unrecoverable in the Court of Claims. Reviewing prior decisions, the Court said payments made under duress or by compulsion may be refunded, but where an applicant pays a stated price without protest or notice and there is no official ruling forcing payment, the payment is voluntary. The Court warned that allowing all such suits would overload the Court of Claims and that Congress had not plainly waived the rule requiring protest or otherwise authorized recovery in every such case. The Court concluded this transaction was a voluntary payment, a mutual mistake of law, and not a basis for judgment against the government.

Real world impact

Because the payment was voluntary and no statutory refund procedure applied, the Court reversed and ordered judgment for the Government. Buyers who pay a government price without objection cannot recover the excess in the Court of Claims on these facts; the decision directs aggrieved purchasers to seek relief from Congress or follow any explicit statutory refund process instead.