Benedict v. United States

Background

A federal judge for the Eastern District of New York resigned after more than thirty years on the bench and after reaching age seventy. At the time, his base annual pay had been fixed at $5,000 by law. Separately, another law paid $300 for each criminal-term session a judge actually held in the Southern District of New York; the judge had held all six such terms each year and received $1,800 annually from those payments. He argued that this per-term money should count as part of the salary used to set his lifetime retirement pay under the retiring statute (section 714).

Reasoning

The Court examined what “salary” meant in the retiring statute. It explained that a true salary is a fixed, regular annual payment that does not depend on how many extra sessions a judge actually holds. By contrast, the $300-per-term payments varied with the number of terms held, were paid only for services actually performed, and could be reduced or ended by Congress. Because those payments were extra compensation for particular duties rather than the fixed annual stipend, the Court agreed they were not part of the salary that the retiring statute protected. The Court affirmed the earlier decision rejecting the judge’s claim.

Real world impact

The ruling means retired federal judges receive the fixed annual salary in effect when they resign, not occasional extra fees for extra sessions. Congress remains able to alter, limit, or eliminate such per-term payments, which are treated as separate, variable pay for extra work.