Does the Holman Rule authorize unconstitutional bills of attainder?

House Republicans have reinstated "the Holman Rule,"a 19th century procedural rule allowing individual congresspersons to propose appropriations cuts targeting very narrow categories -- for instance, the pay of a single civil servant. House Democrats, led by Steny Hoyer, have complained that such surgical strikes on individual federal employee's pay could undermine civil service protection.

Is it an adequate response to Hoyer that any retaliatory appropriations rider directed at a specific civil servant would be barred by the prohibition on bills of attainder contained Article I, section 9? United States v. Lovett (1946) is the most relevant precedent, holding that Congress cannot amend a 1943 spending bill to bar federal funds from being spent on the salaries of three named civil servants. The Lovett majority acknowledged that the spending limit was not literally a criminal penalty but nevertheless found that "[t]he effect was to inflict punishment without the safeguards of a judicial trial and 'determined by no previous law or fixed rule.'"

Of course, the victim of a targeted cut would always have to prove that Congress's motive was retaliatory -- but they would have to do so in an ordinary proceeding before the Merit Systems Protection Board. The civil service laws, after all, do not protect against a mere reduction in force brought on by budget cuts.

So is Representative Hoyer's claim just an alarmist parade of horribles that will never get a marching permit under the Constitution? Or have I over-read Lovett -- an entirely likely possibility, since it has been awhile since I have taught this stuff? (Now that the Holman Rule is back, however, I see a potentially tricky exam question, a silver lining -- at least for law profs --around the cloud of partisan polarization in which we now live).