Overview
Case summary
The Supreme Court reversed a decision of the Court of Claims which had denied the United States interest on a judgment against a postmaster. The lower court had attempted to offset the interest because the government had failed to pay a salary debt to the postmaster for fifteen years. The Supreme Court ruled that under Revised Statutes § 966, the government's right to interest on judgments is absolute and not subject to equitable defenses based on the government's own administrative delays.
Abstract
The Supreme Court reversed the Court of Claims' denial of interest on a judgment against a postmaster, where the lower court had offset the interest due to the government's fifteen-year delay in paying salary owed. The Court held that the government's statutory right to interest on judgments is absolute and cannot be defeated by equitable defenses arising from its own administrative delays. The judgment of the Court of Claims was reversed.
Opinion of the court
opinionMr. Justice Brown
- Interest on judgments in favor of the United States is governed by statute.
- Equitable considerations regarding government laches do not override statutory mandates for interest.
- R.S. § 966 applies to all circumstances within its scope.
Procedural posture
Legal categories
Case record
Issues & holdings
de novo
The Court held that under R.S. § 966, interest must be allowed to the government on judgments without regard to equities that might exist between private parties.
Holdings of the court
Statutory interpretation
1Timeline
No timeline recorded.
Facts & evidence
Key facts
4 facts- A postmaster was sued by the government in 1870 and a judgment was recovered against him.
- At the time of the 1870 judgment, the government owed the postmaster an amount for salary increases that had not been fixed due to the neglect of the Post-Office Department.
- In 1885, the salary increase was finally fixed and the postmaster was credited with $2,892.
- Accounting officers charged the postmaster's estate with interest on the 1870 judgment but refused to allow interest on the deferred salary payment.
Authorities
Legal principles applied
- strict construction of interest statutes