Bartlett v. United States

1905-03-13
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Headline: Treasury clerk’s pay claim denied as Court upheld that a Secretary’s appointment letter did not create extra compensation for disbursing millions to the Washington post office.

Holding: The Court affirmed the Court of Claims, holding that statutory collection districts included the Washington post office and the Secretary’s appointment letter did not create a new paid disbursing office.

Real World Impact:
  • Denies extra pay claim for the clerk who disbursed funds for the Washington post office.
  • Confirms statutory collection districts determine eligibility for extra disbursing pay.
  • Limits the Secretary’s ability to create paid roles by letter alone.
Topics: federal payroll, treasury payments, government compensation, customs collection districts, appointment letters

Summary

Background

A Treasury Department disbursing clerk received a letter from the Secretary of the Treasury appointing him disbursing agent to handle funds for the Washington post office. He gave no new bond or oath. He disbursed nearly two and a half million dollars and sought three-eighths of one percent as compensation. The Court of Claims rejected his claim and he appealed to this Court.

Reasoning

The central question was whether the Secretary’s letter created a paid disbursing role under the statute that allows such appointments only when there is no local customs collector (Rev. Stat. §3658). The Court examined other statutes defining collection districts, especially the provisions placing Georgetown and its surrounding shores in a single district with a collector (§2550, §2551). The Court concluded the Washington post office fell within that collection district, so a collector existed and §3658 did not apply. The 1882 act the claimant cited excluded offices located within the city of Washington and therefore did not help. The Court also found the letter did not create a new office, so prior case law relied on by the claimant was inapplicable.

Real world impact

The decision affirms the lower court and denies the clerk’s extra-pay claim. It makes clear that entitlement to special disbursing compensation depends on the statutes that define collection districts and not simply on an appointing letter from the Secretary. Treasury employees and officials must rely on statutory rules, not informal appointments, to determine pay rights.

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