## Facts

- Charles Richmond, a former Navy civilian welder, received a federal disability retirement annuity due to worsening eyesight.
- Federal law terminated disability benefits if a retiree’s earned income reached at least 80% of the current pay for the pre-retirement position.
- Congress amended the scheme in 1982 so that exceeding the 80% threshold in any single calendar year (rather than in two successive years) ended eligibility.
- Richmond sought guidance from Navy personnel officials to avoid exceeding the earnings cap.
- He received incorrect oral and written advice reflecting the prior version of the statute.
- Relying on that misinformation, Richmond accepted additional work and exceeded the statutory income ceiling.
- OPM denied him six months of disability annuity payments based on statutory ineligibility.
- Richmond claimed the government should be equitably estopped from denying benefits because he reasonably relied on official misinformation.

## Issues

1. Whether equitable estoppel may require payment of federal benefits from the Treasury when a claimant relied on erroneous advice from a federal employee but the payment is barred by statute.
2. Whether the Appropriations Clause prevents courts from ordering money payments not authorized by Congress, even as an equitable remedy.

## Decision

- The Supreme Court reversed the Federal Circuit in a 7–2 decision.
- The Court held that erroneous advice by a government employee cannot estop the government into paying benefits not permitted by statute.
- The Court relied on the Appropriations Clause, which limits Treasury payments to those authorized by statute.
- The Court declined to decide whether estoppel may ever run against the government in non-monetary contexts, resolving the case on the narrower ground applicable to claims for money from the Treasury.

## Legal Principles

- Payments from the Federal Treasury may be made only as authorized by statute; courts cannot order disbursements contrary to statutory limits.
- Equitable estoppel cannot supply a money remedy against the United States when Congress has not authorized the payment.
- Unauthorized oral or written statements by executive-branch employees cannot obligate the Treasury in contravention of congressional spending decisions.
- Misrepresentation-based reliance does not create Treasury liability absent statutory authorization; any exception for reliance-based hardship is for Congress to create.

## Conclusion

The Court held that equitable estoppel cannot be used to compel federal benefit payments barred by statute because the Appropriations Clause restricts disbursement of public funds to amounts Congress has authorized, regardless of a claimant’s reliance on erroneous government advice.


Office of Pers. Mgmt. v. Richmond, 496 U.S. 414 (1990)