District of Columbia v. Eslin

Background

A group of contractors sued to recover money the District of Columbia owed them for work ordered by the District’s Board of Public Works and later by the District Commissioners. Congress had given the Court of Claims power to decide such cases and, by a later law, allowed the Secretary of the Treasury to pay final judgments. The Court of Claims entered judgments for the contractors, and the District sought review in this Court.

Reasoning

Before the Supreme Court could decide the appeal, Congress passed a law repealing the payment authorization and ordering pending proceedings vacated, and it expressly prohibited payment of any judgments rendered under the repealed law. The Court explained that because payment was an act of grace by Congress and the Secretary could no longer lawfully pay, any ruling by the Court would be purely advisory and not enforceable. For that reason the Court said it had no judicial power to render a binding decision on the merits and that a suit to force payment would effectively be a suit against the United States, which cannot proceed without the Government’s consent.

Real world impact

The result is that the contractors’ judgments remain unenforced and their legal rights were not finally decided by the Supreme Court. The dismissal leaves the practical question of payment to Congress or future lawful authorization; the Court did not rule on who was right on the merits and the outcome could change if Congress acts.