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West helps petitioners even less. There, we considered whether the Equal Employment Opportunity Commission (EEOC) could order a federal agency to pay compensatory damages in an administrative proceeding. Section 717(b) of Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e-16(b), authorized the EEOC to employ "appropriate remedies," but did not specifically authorize damages, and §717(c) authorized a subsequent court action against an employer agency, 42 U.S.C. § 2000e-16(c). In 1991, Congress added Rev. Stat. §1977A(a)(1), 42 U.S.C. 1981a(a)(1), which provided that "n an action brought by a complaining party under section 706 or 717 . . . the complaining party may recover compensatory . . . damages." In West, the defendant agency argued that the enactment of §1981a(a)(1) showed that Congress did not consider compensatory damages to be "appropriate remedies" in an EEOC proceeding, as opposed to an action brought by an aggrieved employee. If Congress had wished to authorize the award of compensatory damages in an EEOC proceeding, the defendant agency reasoned, Congress would have so provided in §1981a(a)(l), by expressly cross-referencing §717(c). We rejected this argument, but in doing so we did not hold that an EEOC proceeding is an "action" under §1981a(a)(1). Rather, we simply concluded that the EEOC's authorization under §717(b) to award "appropriate remedies" was broad enough to encompass compensatory damages. 527 U. S., at 220-221.

For these reasons, we are not persuaded by petitioners' argument that the term "action" in §2415(a) applies to the administrative proceedings that follow the issuance of an MMS payment order.

C


We similarly reject petitioners' suggestion that an MMS letter or payment order constitutes a "complaint" within the meaning of §2415(a). Petitioners point to examples of statutes and regulations that employ the term "complaint" in the administrative context. See, e.g., 15 U.S.C. 45(b) (requiring the Federal Trade Commission to serve a "complaint" on a party suspected of engaging in an unfair method of competition); 29 CFR §102.15 (2006) (a "complaint" initiates unfair labor practice proceedings before the National Labor Relations Board). But the occasional use of the term to describe certain administrative filings does not alter its primary meaning, which concerns the initiation of "a civil action." Black's 356. Moreover, even if the distinction between administrative and judicial proceedings is put aside, an MMS payment order lacks the essential attributes of a complaint. While a complaint is a filing that commences a proceeding that may in the end result in a legally binding order providing relief, an MMS payment order in and of itself imposes a legal obligation on the party to which it is issued. As noted, the failure to comply with such an order can result in fines of up to $10,000 a day. An MMS payment order, therefore, plays an entirely different role from that of a "complaint."6

D


To the extent that any doubts remain regarding the meaning of §2415(a), they are erased by the rule that statutes of limitations are construed narrowly against the government. E. I. DuPont de Nemours & Co. v. Davis, 264 U. S. 456 (1924). This canon is rooted in the traditional rule quod nullum tempus occurrit regi-time does not run against the King. Guaranty Trust Co. v. United States, 304 U. S. 126, 132 (1938). A corollary of this rule is that when the sovereign elects to subject itself to a statute of limitations, the sovereign is given the benefit of the doubt if the scope of the statute is ambiguous.

Bowers v. New York & Albany Lighterage Co., 273 U. S. 346 (1927), cited by petitioners, is not to the contrary. There, as here, the issue was the scope of a statute of limitations. The provision in that case, however, provided that " '[n]o suit or proceeding for the collection of any such taxes' " shall commence more than five years after the filing of the return. Id., at 348-349. The Government argued that the terms "proceeding" and "suit" were coterminous, and urged further that any ambiguity should be resolved in its favor.

The Court recognized the canon, restating it much as we have above. Id., at 349. But the Court concluded that the canon had no application in that case because the text of the relevant statute, unlike §2415(a), applied clearly and separately to "suits" and "proceedings," and the Court saw no reason to give these different terms the same meaning. Id., at 349-350.

E


We come now to petitioners' argument that interpreting §2415(a) as applying only to judicial actions would render subsection (i) of the same statute superfluous. Subsection (i) provides as follows: "The provisions of this section shall not prevent the United States or an officer or agency thereof from collecting any claim of the United States by means of administrative offset, in accordance with section 3716 of title 31." 28 U.S.C. 2415(i).

An administrative offset is a mechanism by which the Government withholds payment of a debt that it owes another party in order to recoup a payment that this party owes the Government. 31 U.S.C. 3701(a)(1). Thus, under subsection (i), the Government may recover a debt via an administrative offset even if the Government would be time barred under subsection (a) from pursuing the debt in court.

Petitioners argue that, if §2415(a) applies only to judicial proceedings and not to administrative proceedings, there is no need for §2415(i)'s rule protecting a particular administrative mechanism (i.e., an administrative offset) from the statute of limitations set out in subsection (a). Invoking the canon against reading a statute in a way that makes part of the statute redundant, see, e.g., TRW Inc. v. Andrews, 534 U. S. 19, 31 (2001), petitioners contend that subsection (i) shows that subsection (a) was meant to apply to administrative, as well as judicial, proceedings. We disagree.

As the Court of Appeals noted, subsection (i) was not enacted at the same time as subsection (a) but rather was added 16 years later by the Debt Collection Act of 1982. 96 Stat. 1749. This enactment followed a dispute between the Office of the Comptroller of the Currency (OCC) and the Department of Justice's Office of Legal Counsel (OLC) over whether an administrative offset could be used to recoup a debt where a judicial recoupment action was already time barred.
In 1978, in response to a question from the United States Civil Service Commission, OLC opined that an administrative offset could not be used to recoup a debt as to which a judicial action was already time barred. OLC reached this conclusion not because it believed that §2415(a) reached administrative proceedings generally,7 but rather because of the particular purpose of an administrative offset. "Where [a] debt has not been reduced to judgment," OLC stated, "an administrative offset is merely a pre-judgment attachment device." Memorandum from John M. Harmon, Assistant Attorney General, OLC, to Alan K. Campbell, Chairman, U. S. Civil Service Commission Re: Effect of Statute of Limitations on Administrative Collection of United States Claims 3 (Sept. 29, 1978), Joint Lodging. OLC opined that a prejudgment attachment device such as this exists only to preserve funds to satisfy any judgment the creditor subsequently obtains. Id., at 4 (citing cases). OLC therefore concluded that, where a lawsuit is already foreclosed by §2415(a), an administrative offset that is the functional equivalent of a pretrial attachment is also unavailable. Id., at 3.
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