Wood v. United States

Background

A Navy officer sought higher pay after serving as an aide to the Admiral of the Navy from October 17, 1904, to February 29, 1908. The officer received his regular naval pay as a Lieutenant Commander and later as a Commander, but asked for the higher pay and allowances of a Captain. He argued that a long-standing Army law that gave aides to the General higher rank and pay applied to the Admiral because an 1899 law said Navy officers’ pay should match Army pay. The Court of Claims rejected the claim, and the case came to this Court.

Reasoning

The central question was whether the Army law about aides to the General (Rev. Stat. § 1096) was in force in 1899 so it could be applied to the Admiral. The Court found that § 1096 had ceased when the office of General had previously ended under earlier law, and that a later 1888 statute that briefly made one person General for life did not permanently revive the old provisions. Because Congress did not restore aide pay for the Admiral in subsequent statutes — including a 1908 Navy pay law that listed many pay items but not aide pay for the Admiral — the Court refused to revive a long-expired law by judicial decision.

Real world impact

The ruling means the officer’s claim for extra pay was denied and the Court of Claims’ dismissal was affirmed. Navy officers who act as aides to the Admiral are not automatically entitled to higher pay unless Congress creates such a rule. The decision leaves any change in pay to future legislation rather than to the courts.