Salazar v. Ramah Navajo Chapter, 132 S. Ct. 2181

ISDA directs the Secretary of the Interior to enter into self-determination contracts with tribes for services the agency would otherwise provide.
ISDA requires payment of the full amount of “contract support costs” for each contract, subject to appropriations.
From 1994–2001, Congress appropriated lump sums not to exceed certain amounts for contract support costs, with per-contractor costs potentially funded in full but total costs possibly exceeding the cap.
The Government paid on a pro rata basis when aggregate costs exceeded appropriations, prompting tribe lawsuits for breach of contract under the Contract Disputes Act.
Cherokee Nation v. Leavitt (2005) and related precedents held that when legally available funds are sufficient to pay individual contracts, the Government cannot fail to pay in full absent a special rule.
The Court held that ISDA’s promise to pay is binding when Congress has provided sufficient legally unrestricted funds for the contracts at issue.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Government must pay each tribe’s contract costs in full.	Tribals: full payment required if funds are legally available.	Government: not obligated to pay more than provided by appropriations per cap.	Yes, pay in full.
Whether § 450j-1(b) ‘not required to reduce funding’ meaning changes liability.	Unrestricted funds available; pro rata policy inappropriate.	Reduction clause controls distribution and can bar full payment.	Not to read as altering liability; full payment required.

Cherokee Nation v. Leavitt, 543 U. S. 631 (U.S. 2005) (contract payments subject to availability of appropriations; full funding if funds are sufficient)
Ferris v. United States, 27 Ct. Cl. 542 (Ct. Cl. 1892) (contractor not charged with knowledge of appropriation administration; recovery allowed when funds are insufficient within broader appropriation)
Dougherty v. United States, 18 Ct. Cl. 496 (Ct. Cl. 1883) (principles of appropriation law; contractor rights under lump-sum appropriations)
Lynch v. United States, 292 U. S. 571 (U.S. 1934) (government obligation to contracts when funds are available)
United States v. Winstar Corp., 518 U. S. 839 (U.S. 1996) (reliability of government contracting; precommitment and long-run interests)
International Union, United Auto., Aerospace & Agricultural Implement Workers of Am. v. Donovan, 746 F.2d 855 (D.C. Cir. 1984) (allocation of lump-sum appropriations and agency discretion)
Arctic Slope Native Assn., Ltd. v. Sebelius, 629 F.3d 1296 (CA Fed. 2010) (discussed in dissent regarding § 450j-1(b) interpretation)