Edward Terry Sanford,
United States v. Morrow — Opinion of the Court
“ In 1912 the Secretary of War wrote to the Speaker of the House of Representatives, stating that the pay of the headquarters clerks who were serving in the Philippines was not commensurate with their work and less than that of any other similar government employees in the Islands, and that as there were 'no means' by which the War Department could remedy this condition, he recommended that Congress insert in the next appropriation for headquarters employees a proviso that the pay of such clerks and messengers be increased 20 per centum while serving in the Philippines. ”
