In Bruner v. United States, the Supreme Court ruled that a federal employee who was involuntarily separated from his job and then reinstated following an appeal is entitled to back pay for the period of separation. The case involved James E. Bruner, a civilian employee of the U.S Navy who was dismissed in 1946 but later reinstated by Civil Service Commission's decision in 1948 after it found his dismissal unjustified. However, he wasn't paid for the intervening period which led him to sue for back pay under Section 6(b) of War Labor Disputes Act (now part of Administrative Procedure Act). The government argued that since Mr.Bruner had obtained other employment during this time, he should not be awarded full back pay as it would constitute double compensation. But Justice Black delivered majority opinion stating that when an unjustified or unwarranted personnel action has been corrected on appeal, "the position temporarily lost becomes 'vacant' within meaning of section providing for payment at regular rates." Therefore, Mr.Bruner was entitled to receive full salary minus what he earned elsewhere during his wrongful termination.

In the dissenting opinion for Bruner v. United States, Justice Minton argued that the majority's decision was inconsistent with previous rulings and failed to consider important factors of the case. He believed that when an employee is injured while performing duties related to their employment, they should be entitled to compensation regardless of whether or not they were on government property at the time of injury. In this case, he felt that Mr. Bruner was acting within his scope as a federal employee when he was injured off-site because his job required him to travel between different locations during work hours. Therefore, according to Justice Minton's interpretation of The Federal Employees' Compensation Act (FECA), Mr.Bruner should have been eligible for workers' compensation benefits from his employer - in this instance being the U.S Government.