United States v. Symonds

Supreme Court of the United States
7 S. Ct. 411, 120 U.S. 46, 1887 U.S. LEXIS 1937 (1887)

ELI5:

Rule of Law:

An executive agency cannot alter a statutory definition of compensation by administrative order; if an officer's services factually fall within the statutory definition of 'at sea,' the officer is entitled to the corresponding statutory pay rate regardless of the agency's classification of the vessel.

Facts:

Appellee Symonds, a Navy lieutenant, was assigned as the executive officer of the training ship New Hampshire.
The ship was stationed in Narragansett Bay and was not in a condition to be safely taken out to the high seas.
Symonds was required to live on board, wear his uniform, mess on the vessel, and was strictly forbidden from living with his family.
His duties were practically identical to those performed by executive officers on cruising ships.
Initially, the Navy paid Symonds according to 'sea pay' rates.
The Secretary of the Navy subsequently issued an order declaring that the New Hampshire would no longer be considered 'in commission for sea service.'
Following this order, the Navy reduced Symonds's compensation to 'shore pay' rates, despite his physical duties, location, and living conditions remaining unchanged.

Procedural Posture:

Symonds sued the United States in the Court of Claims to recover the difference between sea pay and shore pay.
The Court of Claims entered judgment in favor of Symonds.
The United States appealed the judgment to the Supreme Court of the United States.

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Issue:

Does the Secretary of the Navy have the authority to reclassify a naval officer's service as 'shore duty' via administrative order, thereby reducing statutory compensation, when the officer's actual duties on a vessel anchored in a bay meet the statutory criteria for service 'at sea'?

Opinions:

Majority - Justice Harlan

No, the Secretary of the Navy cannot utilize administrative orders to reclassify services as 'shore duty' when they factually constitute 'sea service' as defined by Congress. The Court reasoned that Revised Statutes § 1556 and § 1571 explicitly define pay rates and the concept of sea service. While the Secretary has the authority to issue regulations with the President's approval, these regulations must be consistent with existing statutes. Since Symonds performed his duties under orders, on a vessel employed by authority of law, and was subject to the restrictions of ship life, he was factually 'at sea.' The Court held that the Secretary cannot alter the physical reality of the service or the officer's statutory right to compensation merely by issuing an order declaring the ship to be in shore service.

Analysis:

This case is significant in administrative law as it establishes the supremacy of legislative statutes over executive agency regulations. It affirms that agencies cannot use their rulemaking power to redefine terms in a way that conflicts with the plain meaning or intent of a congressional statute, particularly when it affects the financial rights of government employees. The decision protects officers from arbitrary administrative reclassifications that contradict the factual reality of their service.

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