In the United States ex rel. Skinner & Eddy Corporation v. McCarl, Comptroller General case of 1927, the Supreme Court ruled that a government contractor could not sue for additional compensation beyond what was agreed upon in their contract without congressional approval. The Skinner & Eddy Corporation had built ships for the U.S during World War I and claimed they were owed more money due to increased costs caused by changes made by the government's Emergency Fleet Corporation (EFC). However, their contracts stated that any alterations would not result in extra payment unless approved by Congress. The court held that this clause was binding and rejected Skinner & Eddy’s claim because it did not have Congressional approval as required under its contract with the government.

In the dissenting opinion for United States ex rel. Skinner & Eddy Corporation v. McCarl, Justice Stone argued that the Comptroller General did not have authority to settle and adjust claims against the government in a way that would bind both parties involved without their consent. He believed this power was vested solely in Congress or courts of law, and allowing an administrative officer such as the Comptroller General to exercise it violated principles of separation of powers under Constitution. Furthermore, he contended that even if such power could be delegated by Congress, there were no clear statutory provisions granting it specifically to the Comptroller General at present time.