Cochnower v. United States
Headline: Court limits Treasury Secretary’s power to cut customs inspectors’ pay, ruling that the 1909 law allowing him to 'increase and fix' wages lets him set raises but not reduce established daily pay.
Holding: The Court held that the 1909 law’s phrase "increase and fix" lets the Secretary raise and then set inspectors’ pay but does not authorize reducing an inspector’s established daily wage.
- Prevents Treasury from lowering customs inspectors’ pay under the 1909 statute.
- Requires pay increases to be fixed as stable compensation once set.
- Reverses dismissal and sends the case back to decide owed pay under this rule.
Summary
Background
Cochnower, a longtime customs service employee, was appointed a day inspector at $5.00 per diem and served at that rate until July 1, 1910, when the Treasury Secretary reduced his pay to $4.00 per diem. Cochnower sued in the Court of Claims for the pay difference. The dispute centers on a March 4, 1909 law that authorizes the Secretary to "increase and fix" inspectors’ compensation, not to exceed six dollars per day; the Court of Claims read that law as allowing the Secretary to lower pay and dismissed Cochnower’s claim.
Reasoning
The central question was whether "increase and fix" includes authority to decrease previously set pay. The Court explained that assigning pay is primarily a legislative function and any delegation of that power must be clear. The 1909 law clearly authorizes increases and to "fix" them, and the Court said "fix" implies stability and confirmation. Because Congress did not expressly give power to decrease wages, the Court rejected the view that the Secretary has unlimited discretion to cut inspectors’ pay. The Supreme Court reversed the Court of Claims’ dismissal.
Real world impact
Under this ruling, pay increases set under the 1909 statute carry stability and the Treasury Secretary may not use that grant to reduce an inspector’s established daily wage. The case was sent back to the lower court for further proceedings consistent with this interpretation, which may affect any claims for withheld pay under the statute.
Ask about this case
Ask questions about the entire case, including all opinions (majority, concurrences, dissents).
What was the Court's main decision and reasoning?
How did the dissenting opinions differ from the majority?
What are the practical implications of this ruling?