In the case of Lawrence H. Crandon et al. v. United States (1989), the Supreme Court ruled on whether a former federal employee violated conflict-of-interest laws by accepting employment with a defense contractor shortly after leaving government service, where he had been involved in negotiating contracts for that company. The court held that to establish violation of 18 U.S.C § 209(a) - which prohibits any person from receiving salary or contribution to or supplementation of salary as compensation for his services as an officer or employee of the executive branch - it must be shown that payment was made "as compensation" for government work and not merely because of status as a current or former official. The Court concluded there was no evidence showing Mr. Crandon received payments specifically “as compensation” for his governmental duties; rather, they were part of an employment agreement with Northrop Corporation following his departure from public service. This ruling clarified how conflict-of-interest laws apply to post-government employment and set precedent regarding interpretation and application under Section 209(a).

In the dissenting opinion for Lawrence H. Crandon, et al. v. United States, Justice Scalia argued that the majority's decision to interpret 18 U.S.C § 209(a) as only applicable when a salary supplement is tied to an agreement of future government employment was incorrect and overly narrow. He believed this interpretation ignored clear statutory language prohibiting any supplementation of federal employee salaries beyond what is authorized by law, regardless of whether it's connected with an employment agreement or not. Furthermore, he criticized the majority for creating ambiguity where none existed before in order to justify their use of legislative history in interpreting the statute - a practice he disagreed with unless there was genuine uncertainty about its meaning.