United States v. Crosley
Headline: Ruling lets a Navy lieutenant receive the $200 aid supplement like Army aides but denies 'mounted pay' and related longevity pay, limiting which special Army pay transfers to naval officers.
Holding: The Court held that a Navy lieutenant assigned as an aide is entitled to the $200 annual aid supplement like an Army aide, but is not entitled to mounted pay or related longevity pay.
- Allows Navy aides to receive the $200 annual aid supplement.
- Bars Navy officers from claiming mounted pay and related longevity pay.
- Clarifies equal pay applies only to comparable duties, not Army-only service.
Summary
Background
A Navy lieutenant (junior grade) sought extra pay after serving as an aide to a rear-admiral. He asked for the $200 annual supplement that Army aides to major-generals receive and also claimed “mounted pay” and extra longevity pay tied to mounted service. The claim rested on the Navy Personnel Act, which says naval officers should receive the same pay and allowances, except forage, as Army officers of corresponding rank.
Reasoning
The Court examined whether each extra payment is the kind of compensation the Navy Act was meant to equalize. It concluded the $200 aid allowance is paid for the additional duties of an aide and so falls within the Act’s purpose to give corresponding officers like pay. By contrast, the Court found mounted pay is tied to duties that actually require being mounted, a condition that does not apply in the Navy. The Court therefore affirmed the Court of Claims’ allowance of the $200 aid supplement but reversed the award of mounted pay and any longevity pay based on it.
Real world impact
Navy officers serving as personal aides can receive the $200 annual aide supplement like their Army counterparts. But they cannot collect mounted pay or longevity increases that depend on mounted service, because those compensations are tied to Army-only duties. The decision narrows how Army special-pay items apply to naval personnel and clarifies payroll practice for similar future claims.
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