Office of Pers. Mgmt. v. Richmond - 496 U.S. 414, 110 S. Ct. 2465 (1990)

Rule:

Judicial use of the equitable doctrine of estoppel cannot grant a money remedy that Congress has not authorized. Courts of equity can no more disregard statutory and constitutional requirements than can courts of law.

Facts:

Not wishing to exceed a statutory limit on earnings that would disqualify him from continuing to receive a disability annuity based on his years of civilian service with the Navy, respondent Richmond sought advice from Navy employee relations personnel and received erroneous oral and written information. When Richmond's reliance on the information caused him to earn more than permitted by the relevant statute, petitioner, the Office of Personnel Management (OPM), denied him six months of benefits. The Merit Systems Protection Board denied his petition for review, rejecting his contention that the erroneous advice given him should estop OPM and bar its finding him ineligible for benefits under the statute. The Court of Appeals reversed, ruling that the misinformation estopped the Government, and that the estoppel required payment of benefits despite the statutory provision to the contrary.

Issue:

Can an erroneous advice given by a Government employee concerning claimant's eligibility for disability benefits estop the Government from denying benefits not otherwise permitted by law?

Answer:

No.

Conclusion:

The court held that payments of money from the federal Treasury were limited to those authorized by statute. The Appropriations Clause provided that no money could be paid out of the Treasury unless it had been appropriated by an act of Congress. All parties agreed that the award Richmond sought would have been in direct contravention of the federal statute upon which his ultimate claim to the funds rested, 5 U.S.C.S. § 8337. Richmond pointed to no authority in precedent or history for the type of claim he advanced. The Court had never upheld an assertion of estoppel against the government by a claimant seeking public funds.