A federal court has dismissed a claim for backpay filed by Michael E. Woodward, a sworn officer of the United States Capitol Police, during a government shutdown. The United States Court of Federal Claims ruled that Woodward did not meet the legal requirements for compensation under the Government Employee Fair Treatment Act (GEFTA) for the hours he did not work. This decision affects federal employees who may find themselves in similar situations during future government shutdowns.
The case, Woodward v. United States, was filed on August 17, 2026, under docket number 26-744. The ruling is significant as it clarifies the limitations of GEFTA, particularly regarding employee compensation during lapses in appropriations. With the court's decision, federal employees must understand that they cannot claim backpay for hours not worked, even if the absence was due to circumstances related to a government shutdown.
Michael Woodward, representing himself in the case, argued that he was designated as an excepted employee required to work during the government shutdown that occurred from October to November 2025. However, he claimed he could not report for duty for approximately 168 hours due to a lack of funds for transportation. Woodward's complaint stated that he requested unscheduled sick leave on October 17, 2025, and never returned to work. The Capitol Police had informed him that his absences were unapproved and would be classified as Absent Without Leave (AWOL).
The United States government moved to dismiss Woodward's claims, asserting that he failed to state a claim for which relief could be granted. The court noted that while it must read pro se filings generously, the facts presented by Woodward did not support his claim for backpay. The court emphasized that GEFTA only allows compensation for work performed or approved leave, neither of which Woodward had established in his complaint.
In its ruling, the court stated, "The law pays for work performed or leave approved, and Officer Woodward alleges neither. Accordingly, his claim cannot proceed." Judge David A. Tapp presided over the case and granted the United States' motion to dismiss, concluding that Woodward's allegations did not entitle him to a legal remedy.
The court further explained that GEFTA was designed to ensure federal employees are compensated after a lapse in appropriations ends. It provides protection for furloughed employees and excepted employees who are required to work during such lapses. However, Woodward was not furloughed, and he did not perform any work during the period for which he sought compensation.
In its analysis, the court highlighted that GEFTA does not authorize payment for unworked hours or unapproved absences. It stated, "Officer Woodward's overall contention is that GEFTA's protective purpose should be interpreted broadly. But statutory purpose cannot override statutory text. The text controls." This ruling reinforces the importance of adhering to the specific language of the law when determining eligibility for compensation.
The impact of this ruling is significant for federal employees, particularly those in similar positions as Woodward. It clarifies that financial hardships or inability to report for duty due to circumstances related to a government shutdown do not qualify for compensation under GEFTA. Employees must ensure they are either performing work or have approved leave to be eligible for backpay during such periods.
Looking ahead, the dismissal of Woodward's claim does not preclude him from appealing the decision. However, the court's ruling is clear in its interpretation of GEFTA, making it challenging for Woodward to successfully argue against the established legal framework. There are no related cases pending that would directly impact this ruling, but future cases may arise as more federal employees navigate the complexities of government shutdowns and their implications for compensation.