OPINION OF THE COURT
ALITO, Circuit Judge:
This case arises out of a debt of $800,885 that the Pennsylvania Department of Public Welfare ("Pennsylvania") owed the United States Department of Health and Human Services ("HHS"). HHS notified Pennsylvania of the debt in June 1991. Pennsylvania initially balked at having to pay, but eventually, in June 1993, paid the entire principal amount. The dispute that remains is over the interest on the debt. HHS...
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