The U.S. Supreme Court case Janice R. Lachance, Acting Director, Office of Personnel Management v. Lester E. Erickson Jr., et al., 1997 revolved around the interpretation of a federal statute that governs retirement benefits for former government employees who are reemployed by the federal government after retiring from civil service positions. The court had to decide whether or not an employee's annuity should be reduced when they return to work in a position with lower pay than their previous one and if this reduction should be based on their new salary or their old one. Lester E Erickson Jr., along with other plaintiffs, argued that his annuity should not have been reduced because he returned to work at a lower-paying job post-retirement and it was unfair for him to receive less money than he would have received if he hadn't gone back to work at all. However, the Supreme Court ruled against them stating that under current law (5 U.S.C §8344(a)), an individual’s annuity is subject to reduction upon reemployment regardless of any subsequent changes in pay level.

In the dissenting opinion for Lachance v. Erickson, Justice Scalia disagreed with the majority's interpretation of 5 U.S.C § 7701(c)(1)(B), which allows federal agencies to take disciplinary action against an employee only if "the agency’s action promotes efficiency." He argued that this clause should be interpreted as requiring a direct connection between the misconduct and job performance. The majority held that any violation of a rule or regulation could potentially undermine public trust in government employees and therefore harm efficiency. However, Scalia contended that such broad interpretation would allow virtually any misconduct to justify termination under this statute, rendering it meaningless. He also criticized the court for failing to provide clear guidelines on what constitutes “efficiency,” leaving too much discretion to individual judges and creating potential inconsistencies in future cases.