DAVIS v. United States

CourtUnited States Court of Federal Claims
DecidedFebruary 4, 2025
Docket24-364
StatusPublished

This text of DAVIS v. United States (DAVIS v. United States) is published on Counsel Stack Legal Research, covering United States Court of Federal Claims primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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DAVIS v. United States, (uscfc 2025).

Opinion

In the United States Court of Federal Claims No. 24-364 (Filed: September 27, 2024) (Reissued Following Motion to Certify for Interlocutory Appeal: February 4, 2025)

************************* RODNEY L. DAVIS, et al.,

Plaintiffs,

v.

THE UNITED STATES,

Defendant.

*************************

Kenneth T. Cuccinelli, II, Spotsylvania, VA, for plaintiff. Earl Mayfield, III, Fairfax, VA, of counsel.

Galina I. Fomenkova, Trial Attorney, United States Department of Justice, Commercial Litigation Branch, Civil Division, Washington, DC, with whom were Brian M. Boynton, Principal Deputy Assistant Attorney General, Patricia M. McCarthy, Director, L. Misha Preheim, Assistant Director, for defendant.

OPINION

BRUGGINK, Judge.

This is a lawsuit by current and former members of Congress protesting that they have not received a cost-of-living adjustment (“COLA”) since 2009. They assert that this circumstance violates the Twenty-Seventh Amendment to the United States Constitution. An unsympathetic observer might note that this predicament is of Congress’ own making; after all, Congress sets its own pay, and the fact that there has been no COLA in fifteen years is due to its intentional rejection of what would otherwise have been an automatic COLA comparable to that received by other federal employees.

1 Indeed, as defendant points out, virtually all of the named plaintiffs have voted to cancel some or all of those annual pay raises. Nevertheless, the government has not argued that plaintiffs have waived their right to claim entitlement to those COLAs. Instead, it has moved to dismiss the complaint as beyond the court’s subject matter jurisdiction. The matter is fully briefed, and oral argument was heard on August 23, 2024. For the reasons set out herein, we reject defendant’s motion in part and grant it in part.

BACKGROUND

Article I, Section 6, Clause 1 of the Constitution provides that “The Senators and Representatives shall receive a Compensation for their Services, to be ascertained by Law, and paid out of the Treasury of the United States.” U.S. Const. art. I, § 6, cl. 1. Until 1992, that provision was the only instruction the Constitution offered concerning congressional pay. On May 7 of that year, however, Michigan’s approval of the proposed Twenty- Seventh Amendment supplied the necessary 38th state to bring about ratification, officially enshrining James Madison’s compensation Amendment two hundred years after he had proposed it. The Amendment provides that “No law, varying the compensation for the services of the Senators and Representatives, shall take effect, until an election of Representatives shall have intervened.” U.S. Const. amend. XXVII. Because each Congress has a two-year duration, the Amendment ensures that no particular Congress can increase or decrease its own pay. The change in compensation must await the seating of a new Congress.

In addition to these constitutional provisions, there are two pieces of legislation that control congressional pay. The first is found at 2 U.S.C. § 4501. In bare terms, it provides that:

(1) The annual rate of pay for [members of Congress]–

....

shall be the rate determined for such positions under chapter 11 of this title, as adjusted by paragraph (2) of this section.

(2)(A) Subject to subparagraph (B), effective at the beginning of the first applicable pay period commencing on or after the first day of the month in which an adjustment takes effect under section 5303 of title 5 in the rates of pay under the General

2 Schedule . . . as determined under section 704(a)(1) of the Ethics Reform Act of 1989. The appropriate date under this sentence is the first day of the fiscal year in which such adjustment in the rates of pay under the General Schedule takes effect.

2 U.S.C. § 4501(1), (2)(A). Section 4501 thus ties congressional pay increases to the automatic COLA process implemented by § 704(a)(1) of the Ethics Reform Act of 1989 (“ERA”), which applies more generally to civilian employees, including members of the Judiciary. See Ethics Reform Act of 1989, Pub. L. No. 101-194, § 704(a)(1), 103 Stat. 1716, 1768. Section 4501, then, dictates that each year’s COLA, calculated using the formula in the ERA, shall take effect “at the beginning of the first applicable pay period commencing on or after the first day of the month in which an adjustment” of the General Schedule (“GS”) rate of pay for federal employees vests. § 4501(2)(A). The percentage change of COLAs for members of Congress in a given year may not exceed the percentage increase in the GS pay rate for that year. 1 § 4501(2)(B).

Annual adjustments of the GS pay rate, in turn, are set by 5 U.S.C. § 5303. That act, in its essential terms, provides that the GS rates shall automatically increase “by the percentage (rounded to the nearest one- tenth of 1 percent) equal to one-half of 1 percentage point less than the percentage by which the ECI[ 2] for the base quarter of the year before the preceding calendar year exceeds the ECI for the base quarter of the second year before the preceding calendar year (if at all).” 5 U.S.C. § 5303(a). The official table of GS rates (reflecting the changes under § 5303) is announced in an executive order in the December preceding the January in which the new rates take effect. This increase vests on the “first day of the first applicable pay period beginning on or after January 1 of each calendar year.” Id. The congressional COLA thus takes effect automatically each year following the above steps unless Congress abrogates or modifies it

1 The president may modify the annual GS increase if “because of national emergency or serious economic conditions affecting the general welfare, the President should consider” the adjustment “to be inappropriate.” 5 U.S.C. § 5303(b)(1). This may affect congressional COLAs because their amount is capped by the percentage of GS increases. 2 The ECI, or Employment Cost Index, is a measure of employee wages and benefits on a national scale. It is reported quarterly by the Department of Labor.

3 statutorily.

The ERA was the long-sought mechanism by which it was hoped politics would be taken out of the messy process for determining pay for Congress, the Judiciary, and all civilian federal employees. The hope was that, by using an automatic, objective device for determining COLAs, there would be no occasion for salaries to trigger political debate on an annual basis. With respect to members of Congress, the law eliminated many alternative sources of income. See Ethics Reform Act § 601, 103 Stat. at 1760–61. The exchange was that congressional compensation would at least keep pace with inflation through virtually guaranteed COLAs. See id. § 704, 103 Stat. at 1768. This removed the necessity of members casting public votes to set their own salary because the ERA would automatically adjust member pay each year according to its COLA formula.

The application of the ERA to Congress was challenged in Boehner v. Anderson, 809 F. Supp. 138 (D.D.C. 1992).

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