Roberts v. United States

Background

A contractor named Charles E. Evans received two board-of-audit certificates dated August 1, 1874, showing the District owed him money. The District’s authorities kept the certificates as collateral and left them in the Treasurer’s custody until 1890. Evans’s assignee Fisher sued in the Court of Claims, the suit was narrowed to the two certificates, and a judgment was entered and paid by the Treasurer in September 1890 with interest at 3.65 percent. The certificates and their interest later passed through Robinson to Marie A. Valentine, who demanded the additional 2.35 percent interest authorized by an 1894 law. The Treasurer refused, and lower courts ordered him to pay; the case came to this Court for review.

Reasoning

The Court asked whether paying the Court of Claims judgment counted as “redeeming” the certificates under the 1894 law and whether a court could force the Treasurer to pay. The Court said that the judgment declared the certificates valid and that when the Treasurer paid that judgment he effectively redeemed the certificates for the statute’s purposes. The Treasurer’s objections — that he had no internal record showing the underlying claim, that he had not physically redeemed certificates, and that the relator was not the owner at the moment of payment — were rejected. The statute plainly required payment of the extra interest when the Treasurer had redeemed certificates, and that duty was ministerial. The Court therefore affirmed the writ ordering payment.

Real world impact

People who held or later acquired these specific District certificates can collect the extra 2.35 percent interest when the Treasury handled redemption by paying a judgment. The decision treats a Treasury payment of a judgment as a redemption for statutory payment purposes and allows courts to compel a government official to perform a clear statutory payment.