Totten v. United States

In Tenet, which involved a contract claim against the CIA brought by Cold War era spies, Court clarified that “Totten precludes judicial review in cases .

[5] After his death, Lloyd's estate, represented by its executor Enoch Totten, filed suit to recover the promised wages.

Writing for the majority, Justice Field held: In July 1861, in the midst of the American Civil War, William Alvin Lloyd was allegedly recruited as a Union spy by President Abraham Lincoln.

His mission was to collect intelligence on the movements and positioning of Confederate States of America troops and other information useful to the Union war effort.

[10] Although the exact details of the employment contract were disputed—and the only other party, President Lincoln, had been assassinated—Lloyd claimed that he was to be paid $200 per month for his service, which would have totaled $9,753.32 by the end of the war.

[10] But rather than paying him in full, Secretary of War Edwin Stanton agreed to reimburse Lloyd only for expenses incurred in the course of his service, totaling $2,380.

[10][5] After his death, Lloyd's estate, represented by its executor Enoch Totten, filed suit to recover the promised wages.

[5] But the court was equally divided on whether the President of the United States had the authority to unilaterally bind the government to such a contract and opted to dismiss the claim.

The Waite Court in 1876.