Hooe v. United States

Background

A pair of property owners sued the United States seeking $9,000 for the Government’s long use of their Washington building. The Civil Service Commission began occupying the building on August 1, 1900, under a written lease for $4,000 a year that excluded the basement. Over several years the Commission used the entire building, Congress annually appropriated fixed sums for rent (mostly $4,000 or $4,500), and the owners sometimes demanded higher rent and the basement’s value but accepted and receipted the appropriation amounts except for the basement.

Reasoning

The Court asked whether a federal officer can obligate the Government to pay more than Congress has approved. Citing statutory rules that spending cannot exceed congressional appropriations, the Court held the Secretary of the Interior had no power to bind the United States to contracts exceeding those appropriations. Because Congress had specified sums each year and the owners received those sums, the Government could not be held liable for extra rent. The Court also rejected a constitutional “just compensation” claim, explaining that an officer’s unauthorized taking is not the act of the Government, so relief must come from Congress, not the courts.

Real world impact

The decision means landlords and contractors who deal with federal offices cannot force the United States to pay beyond amounts Congress has appropriated. Owners who feel underpaid must petition Congress for additional compensation. Government officials cannot create enforceable obligations that exceed legislative spending limits.