United States v. Shannon

96 L. Ed. 2d 321 · Supreme Court of the United States · 1952

Facts

Boshamers' property was damaged by US soldiers. They later sold the property to Shannons, assigning their claim against the US for the damage. Shannons sued the US, joining the Boshamers, and won in lower courts, which deemed the assignment valid despite the Anti-Assignment Act.

Issue

Does the Anti-Assignment Act invalidate a voluntary assignment of a claim against the United States for property damage, even when the assignors are joined in the lawsuit and the assignment was part of a property sale?

Holding

Yes, the Supreme Court held that the assignment was invalid under the Anti-Assignment Act, reversing the lower courts' judgments in favor of the assignees. The Act's prohibition cannot be circumvented by joining assignors or claims of mistake or hardship.

Rule

The Anti-Assignment Act (R. S. § 3477) renders all voluntary assignments of claims against the United States null and void unless made after the claim is allowed, its amount ascertained, and a payment warrant issued. Exceptions are limited to transfers by will and general assignments for creditors, not voluntary sales for consideration.

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