United States v. Miller
Headline: Navy flag lieutenant pay affirmed but longevity calculation limited: Court upholds $200 aide allowance for officers serving as aids, and bars that allowance from boosting longevity pay.
Holding: A naval flag lieutenant who performs the duties of an admiral’s aide is entitled to the $200 annual aid allowance, but that temporary allowance cannot be included when computing longevity pay.
- Flag lieutenants performing aide duties qualify for $200 annual aid pay.
- Longevity pay cannot be calculated on temporary aid allowances.
- Longevity increases must be based on an officer’s base grade pay.
Summary
Background
William G. Miller, a Navy lieutenant, served as flag lieutenant on Rear Admiral Kautz’s personal staff from July 1, 1899, to March 2, 1900. Miller sued in the Court of Claims seeking a $200 annual allowance paid to an admiral’s aide and additional longevity pay calculated including that allowance. The Court of Claims ruled for Miller on both claims, and the United States appealed.
Reasoning
The Court considered two questions: whether a flag lieutenant is entitled to the $200 aid allowance, and whether longevity pay should be computed using that allowance. The Government relied on Navy regulations that distinguish a flag lieutenant from junior aides, but the Court relied on the Secretary of the Navy’s explanation that the flag lieutenant functions as the senior aide and performs aide duties. The Court therefore affirmed entitlement to the $200 annual aid allowance. As to longevity pay, the Court examined the statutes, including an 1882 amendment requiring longevity increases to be computed on the yearly pay of the officer’s grade, and held that the $200 special allowance is not the yearly pay of the grade and cannot be included when computing longevity increases.
Real world impact
The ruling means officers performing senior aide duties as flag lieutenants may receive the $200 annual aid allowance, but that temporary allowance will not increase longevity pay. The Court modified the lower court’s judgment to remove any longevity increase based on the extra allowance while leaving the $200 award intact.
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