Salter v. United States
119 Fed. Cl. 359
Fed. Cl.2014Background
- Robert L. Salter, Jr. was convicted in 2004 and sentenced to prison and a $50,000 fine; while incarcerated his earnings and gifts were deposited into an inmate trust account and he was enrolled in the Bureau of Prisons (BOP) Inmate Financial Responsibility Program (IFRP).
- The IFRP requires inmate consent to apply trust-fund money toward court-ordered fines; refusal can trigger adverse consequences under 28 C.F.R. §545.11(d) (e.g., loss of furlough, loss of performance pay, stricter commissary limits).
- Salter alleged his consent was coerced by threatened IFRP consequences, that BOP officials were incentivized (compensated/evaluated) based on IFRP participation rates, and that BOP improperly set/modified the timing and amount of his fine payments (usurping judicial authority).
- The government moved for summary judgment arguing (1) Salter lacked standing to attack threatened IFRP consequences unless he suffered them, (2) no evidence supports the compensation/evaluation incentive allegation, and (3) BOP lawfully administered payment timing/amounts consistent with the sentencing order.
- The court found Salter has standing to challenge alleged fiduciary breaches, but granted summary judgment for the government on (a) no admissible evidence that BOP employees’ pay/evaluations were tied to IFRP participation and (b) BOP did not usurp judicial authority because the sentencing order authorized payments during incarceration.
- On the fiduciary/duress claim, the court held governmental trustee duties differ from private trustees; coercion/duress requires wrongful or unlawful conduct and the threatened IFRP consequences were lawful and penologically reasonable, so participation was not involuntary.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Were BOP employees compensated/evaluated based on IFRP participation? | Salter: employees’ evaluations/pay were tied to IFRP participation (conflict of interest). | Gov: no evidence supports that; declaration disproves it. | Court: No admissible evidence — summary judgment for government. |
| Did BOP coerce Salter into consenting to IFRP (breach of fiduciary duty/duress)? | Salter: threatened consequences rendered consent involuntary; trustee must not coerce beneficiary. | Gov: threatened consequences are lawful incentives tied to penological interests; not wrongful. | Court: Government trustee standards differ; coercion requires wrongful/unlawful conduct — none shown; summary judgment for government. |
| Did BOP usurp judicial authority by setting/modifying fine payments? | Salter: BOP set timing/amount of payments, impermissibly exercising judicial power. | Gov: sentencing order set payment schedule during incarceration; BOP merely administered it. | Court: Sentencing order authorized payments during incarceration; no usurpation — summary judgment for government. |
| Standing to challenge IFRP consequences | Salter: challenges use of consequences to coerce release of funds so he has standing. | Gov: inmate must refuse IFRP and suffer consequences to have standing. | Court: Salter has standing to challenge alleged fiduciary breaches because claim targets coercive use of trustee power. |
Key Cases Cited
- Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment standard)
- Anderson v. Liberty Lobby, 477 U.S. 242 (summary judgment/genuine issue standard)
- McKune v. Lile, 536 U.S. 24 (2002) (prison incentives/penological interests do not necessarily coerce involuntary statements)
- United States v. Lemoine, 546 F.3d 1042 (9th Cir. 2008) (IFRP incentives do not render agreements involuntary)
- Johnpoll v. Thornburgh, 898 F.2d 849 (2d Cir.) (IFRP serves penological interests)
- James v. Quinlan, 866 F.2d 627 (3d Cir.) (IFRP reasonably related to rehabilitative goals)
- United States v. Sawyer, 521 F.3d 792 (7th Cir.) (BOP administration of payment schedules lawful)
- Ingram v. Lewis, 37 F.2d 259 (10th Cir.) (trustee withholding beneficiary income can constitute duress in private-trust context)
- Radich v. Hutchins, 95 U.S. 210 (duress requires wrongful/threatened exercise of power)
- United States v. Jicarilla Apache Nation, 131 S. Ct. 2313 (2011) (government fiduciary role differs from private common-law trustee)