Cummins v. United States

Court of Appeals for the Federal Circuit·Decided August 14, 2026·No. 24-2166·Unpublished

Opinion

NOTE: This disposition is nonprecedential.

United States Court of Appeals for the Federal Circuit

SHIRLEY Y. M. CUMMINS, DAVID P.

GIAMELLARO, CAROLYN A. GONZALEZ, ALBERT E. MILLER, ROSA CARMINA RODRIGUEZ, FOR THEMSELVES, ON BEHALF OF ALL PERSONS SIMILARLY SITUATED, AND AS REPRESENTATIVES OF THE PLAINTIFF CLASS CERTIFIED IN CARABALLO V. U.S., CIVIL NO.

1997/27(D. V.I. 2000), Plaintiffs-Appellants

v.

UNITED STATES, Defendant-Appellee

2024-2166

Appeal from the United States Court of Federal Claims in No. 1:23-cv-00308-KCD, Judge Kathryn C. Davis.

Decided: August 14, 2026

ROBERT G. MULLENDORE, Robert G. Mullendore, P.S., Missoula, MT, argued for plaintiffs-appellants.

GALINA I. FOMENKOVA, Commercial Litigation Branch, 2 CUMMINS v. US

Civil Division, United States Department of Justice, Washington , DC, argued for defendant-appellee. Also represented by CLAUDIA BURKE, PATRICIA M. MCCARTHY, BRETT SHUMATE.

Before REYNA, SCHALL, and CUNNINGHAM, Circuit Judges. REYNA, Circuit Judge.

Plaintiffs in this class action case are current or retired federal employees who have lived and worked in non-foreign areas outside the contiguous United States. Plaintiffs asserted claims against the United States for underpayment of salary and retirement benefits. The United States Court of Federal Claims dismissed their claims for lack of subject-matter jurisdiction. For the reasons below, we affirm .

BACKGROUND

In 2023, current and retired federal employees living in “non-foreign areas” of the United States brought suit against the government for underpayment of salary and retirement benefits. Non-foreign areas are, inter alia, “States, commonwealths, territories, and possessions of the United States outside the 48 contiguous United States.” 5 C.F.R. § 591.205. These include, for example, Hawaii, Alaska, and Puerto Rico. Id.

I.

This case concerns two components of non-foreign federal employees’ salaries: cost-of-living allowances and locality pay. We begin with a discussion of the statutory framework for each.

A. Cost-of-Living Allowances Federal employees in non-foreign areas receive a cost-

of-living allowance (“COLA”) pursuant to 5 U.S.C. § 5941 and Executive Order No. 10,000. Historically, COLA rates

CUMMINS v. US 3

were based on “(1) living costs substantially higher than in the District of Columbia; (2) conditions of environment which differ substantially from [those] in the continental United States and warrant an allowance as a recruitment incentive; or (3) both of these factors,” but were capped at 25 percent of the rate of basic pay. 5 U.S.C. § 5941(a) (1966).

Under the Civil Service Retirement System (“CSRS”)

and the Federal Employees Retirement System (“FERS”), “basic pay” is the salary a federal employee receives for purposes of retirement calculations. See 5 U.S.C. §§ 8331(3), 8401(4). The statutes explicitly exclude certain types of pay from basic pay, including “bonuses, allowances , overtime pay, [and] military pay.” 5 U.S.C. §§ 8331(3), 8401(4). The Office of Personnel Management (“OPM”) has interpreted these statutes to exclude COLA from basic pay for purposes of retirement calculations.

OPM conducted annual surveys to determine COLA rates until Congress changed the compensation scheme for non-foreign employees in 2009, as discussed in Section I.B.2, infra. See 5 C.F.R. § 591.223 (dividing non-foreign areas into three groups and explaining that “OPM conducts a survey in each COLA area once every 3 years on a rotational basis”).

B. Locality Pay

1. Federal Employees Pay Comparability Act of 1990 (“FEPCA”)

In 1990, Congress introduced locality-based comparability payments to offset pay disparities among federal and non-federal workers doing “the same levels of work” within a given locality. Federal Employees Pay Comparability Act of 1990, Pub. L. No. 101-509, § 529, 104 Stat. 1389; see also 5 U.S.C. § 5304(d)(1)(A). Congress instructed the President to direct an agent to prepare a report that (A) compares rates of pay of federal and non-federal workers in 4 CUMMINS v. US

each locality, (B) identifies each locality in which a pay disparity exists and specifies the size of the disparity, and (C) recommends comparability payments to reduce pay disparities . 5 U.S.C. § 5304(a), (d)(1)(A)–(C) (1990). Congress further instructed the President to “provide for or adjust comparability payments” based on the report. See id. § 5304(d)(2).

Locality pay differs from COLA in that it is considered part of “basic pay” for retirement purposes. See id. § 5304(c)(2)(A).

Congress explicitly excluded employees in non-foreign areas from being included in a “pay locality.” See id. § 5304(f)(1)(A) (providing that “each General Schedule position (excluding any outside the continental United States, as defined in section 5701(6)) shall be included with a pay locality” (emphasis added)). 1 2. Non-Foreign AREA Act of 2009 The exclusion of COLA and inclusion of locality pay in retirement benefits calculations for non-foreign and contiguous United States employees, respectively, created disparities in retirement benefits among federal workers in non-foreign areas versus those in the contiguous United States. To eliminate these disparities, Congress expanded the locality pay system to include non-foreign area federal employees. 5 U.S.C. § 5304(f)(1)(A) (2009); see also Non- Foreign AREA Act of 2009, Pub. L. 111-84, §§ 1911–19, 123 Stat. 2190, 2619–27 (amending 5 U.S.C. §§ 5304, 5941 and 39 U.S.C. § 1005(b)).

Congress provided guidance for introducing locality pay and phasing out COLA in a manner designed to protect

1 The term “‘continental United States’ means the several states and the District of Columbia, but does not include Alaska or Hawaii.” 5 U.S.C. § 5701(6).

CUMMINS v. US 5

employees’ take home pay. See Non-Foreign AREA Act §§ 1914–15, 123 Stat. 2621–22. Congress phased in locality pay for non-foreign employees over a period of three years and transitioned COLA from an annual calculation to a set formula such that it could be gradually phased out. See id. § 1914, 123 Stat. 2621 (5 U.S.C. § 5304 Note providing transition schedule for locality-based payments for each non-foreign area); 5 U.S.C. § 5941(c)(2)(B).

To determine locality pay for the newly eligible non-

foreign employees, Congress suggested that the Bureau of Labor Statistics conduct “separate surveys to determine the extent of any pay disparit[ies]” in non-foreign areas. Non-Foreign AREA Act § 1915(a)(3), 123 Stat. 2621–22. Congress further suggested each area with a pay disparity exceeding a threshold be treated as a separate pay locality. Id. § 1915(a)(4), 123 Stat. 2621–22.

II.

Plaintiffs filed a class action complaint in the United States Court of Federal Claims (“Federal Claims Court”) in March 2023. Plaintiffs filed an amended complaint in August 2023, asserting six claims falling into two categories: four claims pertaining to salary and two for retirement benefits. J.A. 38–41. In their salary claims, Plaintiffs alleged entitlement to locality pay during the period from January 1, 1994, through December 31, 2009. Plaintiffs also alleged continuing entitlement to COLA at the rates that were in effect on December 31, 2009. Plaintiffs contended that their exclusion from locality pay and Congress ’s phase-out of COLA constituted violations of due process and equal protection guaranteed by the Fifth Amendment and unconstitutional bills of attainder. In their retirement benefits claims, Plaintiffs argued that the government’s agencies must correct their payroll records to reflect the amounts of locality pay that Plaintiffs were entitled to receive during the period from January 1, 1994, through December 31, 2009, and must pay, with interest, 6 CUMMINS v. US

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