Hart v. United States

United States Court of Federal Claims·Decided July 27, 2026·No. 25-1376·Published

Opinion

In the United States Court of Federal Claims

SHARON Y. HART

Plaintiff,

v. No. 25-1376 Filed July 27, 2026 THE UNITED STATES,

Defendant.

Sharon Y. Hart, Štore, Slovenia, pro se. Elinor J. Kim, Civil Division, United States Department of Justice, Washington, DC, for defend- ant.

OPINION AND ORDER Granting the government’s motion for judgment on the pleadings and denying Dr. Hart’s cross-motion for judgment on the pleadings

Sharon Hart, proceeding without an attorney, seeks Sunday differential pay that she alleges

the United States Agency for International Development owes but did not pay her under a personal

services contract. The government moves for judgment on the pleadings and asks the court to

dismiss the complaint for failure to plausibly allege that USAID was required to pay Dr. Hart at

the rate she asserts. Dr. Hart cross-moves for judgment on the pleadings.

The government is correct that neither the contract nor governing law required USAID to

pay Dr. Hart the higher Sunday differential pay rate she claims, and neither party disputes that

USAID paid Dr. Hart for each Sunday hour she worked at a rate of 25 percent above her basic

hourly rate. The court will therefore grant the government’s motion and deny Dr. Hart’s cross-

motion.

1 I. Background

Dr. Hart contracted with USAID to serve as a senior education and youth advisor in Am-

man, Jordan, from February 4, 2024, through February 1, 2025. ECF No. 1-1 at 1, 4. The contract

identifies Dr. Hart as an offshore personal services contractor. Id. at 1, 3. The contract consists of

a cover page, a schedule, and the relevant Agency for International Development Acquisition Reg-

ulation (AIDAR) and Federal Acquisition Regulation (FAR) clauses. Id. at 1. The contract sets a

Sunday-through-Thursday workweek with an expected eight hours per workday. Id. at 4.

Article IV of the schedule, titled “Contractor’s Compensation and Reimbursement,” sets

Dr. Hart’s position grade at GS-15, step 10. ECF No. 1-1 at 4. It lists an annual basic compensation

of $159,950, corresponding to an hourly rate of $76.64. Id. The same page includes a table titled

“Contract Estimation.” Id. That table lists seven “Budget Categor[ies].” Some of the line-item

budget categories include percentages. The Sunday differential entry lists “25%.” Id. The table

also includes dollar amounts for each budget category in the “Year 1” column. Id. It lists

“$39,987.50” for Sunday differential. Id. The “Total - Contract” is “$243,107.00” for the year. Id.

The entire table is provided below.

2 ECF No. 1-1 at 4.

Article IV then explains some of the line items. ECF No. 1-1 at 4-6. It provides that “a

contractor may be eligible for additional pay ... in accordance with the contract clause entitled

‘Differentials and Allowances.’” Id. at 5 [¶5]. It also describes the table as a “budget,” presenting

the “total estimated cost budgeted for compensation, fringe benefits, and other direct costs,” “cal-

culated to cover the period of February 04, 2024 through February 01, 2025.” Id. at 5. Article IV

labels the total the “Maximum U.S. Dollar Obligation,” which “must not exceed $243,107.00.” Id.

at 5; see also id. at 1; ECF No. 14-1 at Appx110-11.

Before the parties executed the contract, USAID sent Dr. Hart a nonbinding “Conditional

Selection Letter.” ECF No. 1-1 at 34. That letter lists “Sunday Premium Pay - currently at the rate

of 25%” among the “benefits and allowances” for which Dr. Hart may be eligible. Id. The letter

also states that USAID grants those benefits and allowances “in accordance with [AIDAR] Ap-

pendix D.” Id.

The parties do not dispute that Dr. Hart worked 224 Sunday hours in 2024 and 32 Sunday

hours in 2025, totaling 256 Sunday hours. ECF No. 1-1 at 45-46; ECF No. 11 at 1 [¶3]. USAID

paid her $4,910.24 in Sunday differential pay: $4,291.84 for 2024 and $618.40 for 2025. ECF No.

1-1 at 45; ECF No. 14 at 6-7. That is approximately equal to 25 percent of her hourly rate of $76.64

times the total 256 Sunday hours. (Dr. Hart was paid slightly more because her hourly rate in-

creased to $77.30 in 2025. See ECF No. 14 at 3 n.4, 7.)

Dr. Hart alleges that USAID miscalculated her Sunday differential pay rate. She reads the

“$39,987.50” entry in the table as the amount USAID expected to pay for the full year, assuming

eight-hour Sunday workdays every Sunday. ECF No. 1-1 at 46. From that assumption, Dr. Hart

derives a rate of $96.12 in differential pay per Sunday hour, by dividing $39,987.50 by 416 total

3 possible Sunday hours. Id. She then multiplies $96.12 by the 256 Sunday hours she worked, yield-

ing $24,606.72. Id. After subtracting the $4,910.24 USAID paid her, Dr. Hart seeks an additional

$19,696.48 in Sunday differential pay. Id.; ECF No. 1 at 2.1

In January 2025, Dr. Hart submitted a written claim to the executive office director, Dr.

Cynthia Rogers, alleging that USAID had miscalculated her Sunday differential pay. ECF No. 1-

1 at 41-42. Dr. Rogers responded that because the contract was not “fixed price,” the amount it

listed for Sunday differential pay was only a “budget estimate” that “must be in excess so that

[USAID] never fall[s] short.” Id. at 38-39. Dr. Rogers explained that USAID pays contractors

Sunday differential pay “under the same terms and conditions that apply to noncommissioned

[Foreign Service] Direct-Hire employees.” Id. at 39. Dr. Rogers added that she could not approve

payment above the rate the Office of Personnel Management set. Id. at 38.

Dr. Hart later contacted USAID’s personal services contract ombudsman. ECF No. 1-1 at

37, 44. She filed this suit in August 2025. ECF No. 1. The government moves for judgment on the

pleadings and to dismiss the complaint. ECF No. 14. It argues that the contract required USAID

to pay Sunday differential pay at only 25 percent of her basic hourly rate for each Sunday hour

worked, resulting in the amount she already received. Id. at 2. Dr. Hart opposes and cross-moves

for judgment on the pleadings, arguing that the “$39,987.50” entry in the table entitled her to a

higher rate, which, when prorated for the actual number of hours she worked, should result in her

receiving an additional $19,696.48 in Sunday differential pay. ECF No. 15 at 3.

1 The government explains that, even though Attachment 6 in Dr. Hart’s initial complaint says “415” (ECF No. 1-1 at 46), that was evidently a typo. ECF No. 14 at 12 n.10. The number of Sunday hours per year works out to 52 times 8 equals 416. And, in fact, Dr. Hart’s own math works with the number 416, not 415, as $39,987.50 divided by 416 equals Dr. Hart’s calculated rate of $96.12 per hour. See ECF No. 1-1 at 46.

4 II. Discussion

This court’s jurisdiction is primarily defined by the Tucker Act, which provides the court

with exclusive jurisdiction to decide specific types of monetary claims against the United States.

Kanemoto v. Reno, 41 F.3d 641, 644 (Fed. Cir. 1994); 28 U.S.C. § 1491(a)(1). The Contract Dis-

putes Act, Pub. L. No. 95-563, 92 Stat. 2383, 2388 (1978), amends the Tucker Act and provides

the court with “jurisdiction to render judgment upon any claim by or against, or dispute with, a

contractor arising under [41 U.S.C. § 7104(b)(1)] ...

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