the Claims Court to report on whether Paul's claim was a legal, equitable, or gratuitous claim and what amount was legally or equitably due him by the United States. Holding In a detailed holding, Hearing Officer Kenneth Harkins examined the court's entire Congressional reference jurisdiction and found that the court was not required to view the resolution as being favorable towards Paul, that the legal theories of res judicata and stare decisis do not apply to Congressional reference cases, and that any findings of the court are merely advisory to Congress. Harkins found that there was no legal grounds for the government to pay Paul, and that even under the wider Congressional concept of "broad moral principles of right and justice", there were not equitable grounds for payment to Paul. Harkins also found that in such cases, "equitable" can have two meanings, both the traditional meaning of "equity at law" and the broader meaning of "upon considerations of a moral or merely honorary nature". He stated that under the traditional theory of equity, there was no action possible, as equity deals with things "such as reformation of contracts, or mandamus orders to government officials who have failed to follow statutory commands", and this was a request for payment of money. Even under the broader theory of equity as a "moral action", Harkins did not find a duty to pay him additional funds. However, he did hold that if Congress were to pay him funds in light of his contributions to the development of native government, it would be as an equitable claim and not a gratuity. Review panel Paul appealed the hearing officer's report to a review panel consisting of Judges James T. Turner, Bohdan A. Futey, and Roger Andewelt of the Claims Court. He claimed that Harkins was incorrect in holding he lacked a broader equitable claim against the United States under the Congressional reference sense of the term. The panel held that Harkins was accurate in holding there was no legal or equitable claim under any sense of the words and further held that Harkins was incorrect in holding that payment of the claim would be payment of an equitable claim. The panel instead held that if Congress were to pay the claim, it would be as a gratuity, due to the poor record keeping that supported the amount of his claim and for the other reasons that