United States v. Shannon

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

Facts

The Boshamers owned land, including two unleased tracts with buildings that were damaged by U.S. soldiers in 1945. In 1946, the Boshamers sold the entire property to the Shannons (respondents), including an agreement to release any claim against the U.S. for property damage to the purchasers. The Shannons then sued the U.S. under the Federal Tort Claims Act, joining the Boshamers, who had refused to pursue the claim themselves.

Issue

Does the Anti-Assignment Act (R. S. § 3477) invalidate a voluntary assignment of a claim against the United States for property damage, even when the assignors are joined as parties, or when the assignment is part of a land sale and alleged to be a "mutual mistake of law"?

Holding

The Supreme Court reversed the lower courts, holding that the voluntary assignment of the claim against the United States was invalid under the Anti-Assignment Act. The Court found that the Act's prohibition could not be circumvented by joining assignors, claiming mutual mistake of law, or arguing hardship.

Rule

The Anti-Assignment Act (R. S. § 3477) prohibits voluntary assignments of claims against the United States, with narrow exceptions for transfers by operation of law, will, or general assignment for creditors. The Act's purposes include preventing influence peddling, avoiding multiple payments, and preserving government defenses, and it cannot be bypassed by procedural contrivances or equitable arguments like mutual mistake or hardship.

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Case brief last reviewed 2026-03-19. Prepared by CaseReader from the published opinion.