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2022 Procurement Review--Contract Disputes



 

Boards of Contract Appeals (ASBCA, CBCA, PSBCA, and GAOCAB)

Jurisdiction/Standing/Timeliness/Contract Disputes Act (CDA) Issues    

In RDG Breton, LLC, the CBCA denied the Government's preliminary jurisdictional motion to dismiss the portion of a delay claim for "carried interest" because the delay claim is a CDA claim over which the Board has jurisdiction even though, after the record is developed, the Board may ultimately decide the particular interest issue may be covered by the "no interest" rule, which is an invocation of sovereign immunity to bar the payment of interest for a period prior to a Contracting Officer's decision on a CDA claim.

In ECC Int'l Constructors, LLC, the ASBCA held that it lacked jurisdiction over the Government's claim for liquidated damages because no Contracting Officer's decision had assessed them, and, therefore, the contractor's counterclaim for the same damages should also be dismissed (without prejudice) as moot. Subsequently, however, in considering the Government's motion for reconsideration, the Board held that the Government actually had withheld liquidated damages, that both parties had claimed the right to those sums, and that the Board would proceed to address those competing claims in a separate, yet-to-be-published, decision.

In Avue Technologies, Corp., the CBCA held that it lacked CDA jurisdiction over a claim by a software licensor based upon an alleged violation of its license that was incorporated by a reseller into the reseller's contract with the Government because the license is not a procurement contract under the CDA, the procurement contract being the one between the reseller and the Government.

In AECOM Technical Services, Inc., the ASBCA denied the Government's preliminary motions to dismiss two counts in the contractor's Complaint for failure to state claims upon which relief could be granted because: (i) the contractor made a non-frivolous allegation of a contract with the Government; and (ii) the contractor alleged facts that plausibly suggested the Government owed it money for having kept contractor's work product without paying for it.

In White Balad Co., after raising the issue sua sponte due to the Government's initial question whether there was a contract, the ASBCA held it had jurisdiction over the appeal because: (i) the contractor provided a copy of the contract that the Government then conceded existed; (ii) the contractor submitted a claim for less than $100,000 to the Contracting Officer; (iii) the Government had failed to act on it within a reasonable time; and, therefore, (iv) the contractor had properly appealed from a deemed denial.  

In ECC Int'l, LLC, the ASBCA: (i) denied the Government's motion to dismiss the contractor's breach of the warranty of specifications and breach of the implied duty of good faith and fair dealing claims as failing to state separate sums certain when they were presented to the Contracting Officer because (a) the contactor intended them as two theories of recovery for essentially the same claim and both were based on the same operative facts, and (b) it was to be expected that, following discovery, the contractor would add new factual allegations obtained from discovery without constituting new claims; (ii) the contractor's original claim adequately alerted the Contracting Officer to the facts concerning the superior knowledge allegations first presented as an alternative theory of recovery, rather than as new claim, on appeal; but (iii) the contractor's original claim had not alerted the Contracting Officer to the elements of recovery concerning a claim of commercial impracticability presented for the first time on appeal.

In SupplyCore, Inc., which involved a commercial items contract with fixed-prices for items identified to be supplied by a specific subcontractor, a disagreement between the prime and the sub concerning pricing did not excuse the  prime's failure to deliver on time;. The Board lacked jurisdiction over a count alleging excusable delay because a claim for a time extension was never submitted to the Contracting Officer. However, the Board had jurisdiction over a claim for the Government's alleged breach of the implied duty of good faith and fair dealing raised solely as a defense to the Government's default termination claim. The contractor failed to prove that it was misled by the Contracting Officer's email into thinking the Government was waiving requirements previously the subject of a cure notice when the email clearly identified the requirements to which it referred. The contractor failed to show why it should have been terminated for convenience rather than for cause after it failed to deliver.

In Kentucky Business Enterprise, the ASBCA dismissed (as untimely) an appeal mistakenly filed with the CBCA (with a copy to the Contracting Officer) on the 90th day after receipt of the Contracting Officer's decision and filed with the ASBCA on the 91st day.  

In AECOM Technical Services, Inc., the ASBCA denied the Government's preliminary motions to dismiss two counts in the contractor's Complaint for failure to state claims upon which relief could be granted because: (i) the contractor made a non-frivolous allegation of a contract with the Government; and (ii) the contractor alleged facts that plausibly suggested the Government owed it money for having kept contractor's work product without paying for it. 

In Herren Assocs., Inc., the ASBCA held that the contractor's claims were barred by the six-year limitations period because neither claim was submitted within that time, and neither the "Allowable Cost and Payment" clause nor any other contract clause had the effect of tolling the normal limitations period. 

In HPM Corp., the CBCA denied the contractor's alternative motions to dismiss or for a more definite statement because the Government's Complaint was sufficient to notify the contractor of the nature of the Government's claim that repayment was required for work the contractor did not complete, especially where the record was clear that the contractor did not perform the work in issue, and the contractor would have ample opportunity to flesh out other issues (e.g., the method the Government used to compute quantum) during discovery.

In Wilwood Eng'g Inc., the ASBCA held that: (i) in a claim for wrongful rejection of previously accepted products, the contractor need not allege the reason the Government used for deciding to revoke acceptance; (ii) the Board had jurisdiction over the counts in the Complaint alleging breach of the implied duty of good faith and fair dealing and the implied duty to cooperate with contractor and not to hinder its performance because those counts arose from the same operative facts as those in original claim; and (iii) the count in the Complaint alleging the Government had breached it implied duties by failing to engage in ADR must be dismissed because it had not previously been the subject of a claim. 

In [Redacted], the ASBCA dismissed an appeal for lack of jurisdiction because there was no evidence of any claim apart from one that already had been the subject of a Board decision in 2017

In AAI Corp, d/b/a Textron Systems, Unmanned Systems, the ASBCA: (i) denied the contractor's motion for summary judgment that the Government's TINA claim relating to a subcontractor's price was barred by the CDA limitations period because the cost data supplied to the Government during negotiations was not sufficient to alert the Government to the fact that the contractor had locked in a subcontractor price lower than price used during negotiations; (ii) denied the contractor's motion for summary judgment on the merits of the same issue because the undisclosed firm price reasonably could have affected the negotiations; (iii) granted the contractor's motion for summary judgment that the Government's shelter costs claim was time barred because the Government had all the information necessary to make the claim (namely the proposal itself) more than 10 years before the claim was asserted; and (iv) denied the contractor's motion for summary judgment regarding the limitations period applicable to a labor costs issue because that issue would have been much more difficult than the shelter costs issue for the Government to have discovered from the documents available to it.

In Eagle Peak Rock & Paving, Inc., the CBCA dismissed an appeal filed one day late for lack of jurisdiction because, although the contractor's offices allegedly were not open, its receptionist (who was allegedly not authorized to do so), had signed for a FedEx delivery of the Contracting Officer's decision. 

In Zach Fuentes, LLC, over the Government's objection, the CBCA granted the contractor's new attorneys' request  to file an amended complaint adding a count for breach of the implied duty of good faith and fair dealing several months after the Government had answered the original complaint and after discovery had been conducted because the amended complaint (a) would not unduly prejudice the Government, (b) was based on the same operative facts as the original claim, (c) would not unduly delay the proceedings, and (d) would not be futile. However, the Board held it lacked jurisdiction over the paragraph in the amended complaint alleging bad faith by the Government. 

In Lockheed Martin Aeronautics Co., responding to cross motions for summary judgment as to timeliness, the ASBCA held, inter alia, that claims for allegedly excessive over and above work for certain aircraft pursuant to Manufacturing Deficiency Reports ("MDRs") were timely because, under the continuing claim doctrine, the claims did not have a single accrual date but, instead, had a series of separate accrual dates corresponding to each of the underlying MDRs that the contractor was ultimately required to address. 

In Sungwoo E&C Co, Ltd., the ASBCA: (i) denied the Government's motion to dismiss a claim for an allegedly improper CPAR evaluation due to a defective certification because no certification was required for that nonmonetary claim; (ii) held that the attorney who submitted the certification for another claim was authorized to do so as evidenced by a power of attorney from the contractor's President that the attorney submitted along with the certification; and (iii) concluded that there was no evidence that a foreign law concerning the contractor's receivership cited by the Government impeded the contractor's ability to certify the claim. 

In BCC-UIProjects-ZAAZTC Team JV, the ASBCA held, inter alia, that it lacked jurisdiction over the appeal of a joint venture's claim originally submitted to the Contracting Officer by an individual that, according to the JV agreement, did not have the authority to do so. 

In Zahra Rose Construction & Logistics Services Co., the ASBCA dismissed an appeal filed well after 90 days from the date of the Contracting Officer's decision because the circumstances indicated that the contractor (i) was not prejudiced by either the decision's failure to notify it of its appeal rights or the email address to which the decision was sent and (ii) was not prevented from appealing by the Taliban's takeover of Afghanistan (because the contractor had communicated with the Board several times on other matters during the period when its appeal would have been timely). Subsequently, the Board denied the contractor's motion for reconsideration.

In Bagram Eagle Construction and Logistic Co., the ASBCA dismissed an appeal for lack of jurisdiction because the contractor had not alleged the existence of a contract with the United States. The only allegation was of a contract with another company.  

In DLT Solutions, LLC, the ASBCA held that, although the contractor had properly submitted its claims to the Ordering Activity Contracting Officer rather than GSA schedule Contracting Officer, those of its claims on appeal not previously submitted to any Contracting Officer (i.e., for superior knowledge and fraudulent inducement) must be dismissed, as must its estoppel claim because a portion of that claim sought specific performance or injunctive relief, which the Board lacks jurisdiction to grant, and the remainder of the claim did not assert an independent basis for entitlement to relief.

In Fidelity and Deposit Co. of Maryland, the ASBCA dismissed a surety's appeal for lack of jurisdiction because the surety was not in privity with the Government on the date the claim accrued. The Board reached the same result as a result of similar reasoning in a subsequent appeal involving the same surety.

In Siemens Government Technologies, Inc., the ASBCA held that: (i) it lacked jurisdiction over a claim that the Government had breached duty of good faith and fair dealing by failing to fairly consider appellant's proposal under the implied-in-fact contract created when the appellant submitted that proposal because that implied-in-fact contract is not covered by the CDA; (ii) a preaward breach of good faith and fair dealing cannot establish jurisdiction for a claim involving subsequent task orders; and (iii) the solicitation and contract documents were clear that the Government would not be liable to compensate the appellant for costs incurred on projects that did not result in a task order. 

In ATS Trans LLC dba Around the Sound/TransPro, the CBCA denied the Government's motion to dismiss an appeal for lack of jurisdiction, holding that a corporate merger had established an entity that, by "operation of law," was exempt from the strictures of the Anti-Assignment Act and was, therefore, entitled to perform the contract, to make a claim, and to appeal the denial of the claim to the Board.

In Scot Cardillo dba Engineers Tooling Support, over the contractor's objections, the ASBCA dismissed an appeal as moot because the Contracting Officer had "unequivocally" withdrawn his decision and the Government's claim on which it was based, explicitly acknowledging that the contractor had returned the GFP that had been the subject of the claim.  

In Board of Education for the Gallup-McKinley County Schools, the CBCA held it lacked jurisdiction over a situation where the appellant had sought, but was not awarded, a contract. 

In Raj K. Patel, the CBCA held it lacked CDA jurisdiction over contracts with the Executive Office of the President and over various tort and constitutional claims. 

In Integhearty Wheelchair Van Services, LLC, the CBCA: (i) dismissed a claim for lost profits because the contract was neither a requirements contract nor an IDIQ contract with a guaranteed minimum so the contractor was entitled to payment only for work it actually performed; (ii) held it lacked jurisdiction over a claim of de facto debarment because it involved only subcontracts the contractor claimed it was not awarded rather than the contract at issue; but (iii) declined to dismiss a claim that the COR had acted in bad faith (e.g., retaliating against the contractor after it fired a friend of the COR’s), which allegedly increased the costs of the original contract work. 

In 4K Global-ACC Joint Venture, LLC, the CBCA: (i) granted the agency's motion to dismiss an appeal because a letter from the Contracting Officer to the contractor stating that it was a CDA claim against the contractor, and including the specific amounts claimed, but omitting any statement of appeal rights and inviting the contractor to submit its position on the claim before a final decision was issued, was not, itself, an appealable final decision; and (ii) rejected the contractor's request that the Board direct the Contracting Office to issue decisions on the Government's claims by a date certain because the CDA authorizes such directions only on contractor claims.

In Brightwood Management Partners, the CBCA held it had jurisdiction because "the allegations contained within [the contractor's] certified claim provide the Government with sufficient notice of the basis of [the contractor's] breach of the implied duty of good faith and fair dealing claim. 

In U.S. Army Tactical Supply, the CBCA dismissed an appeal because it involved the same claim for payment as a previous appeal that the contractor had requested be dismissed and that had been dismissed with prejudice.  

In Mission Support Alliance, LLC, the CBCA: (i) denied the contractor's motion that the agency's claims were barred by the six-year limitations period because the grounds for those claims were not reasonably knowable to the agency until shortly before it filed them; and (ii) denied the contractor's appeal on the merits because the contractor had failed to provide adequate documentation to establish the reasonableness of claimed subcontractor costs. Subsequently, the Board denied the contractor's motion for reconsideration.

In Afghan Premier Logistics, the ASBCA held that claims for unpaid amounts accrued when the contractor knew or should have known of the reductions in pay on which the claims were based (i.e., the date the contractor received the returned invoices indicating these reductions) but were not filed within six years thereafter. Subsequently, the contractor's motion for reconsideration was denied.

In Gulf Tech Constr. LLC, the CBCA denied the contractor's motion to stay the appeal and instead dismissed it for lack of jurisdiction because it was based only on an unsigned, uncertified REA that did not explicitly or implicitly request a decision by the Contracting Officer and that was submitted only for purposes of initiating negotiations. 

In DeNapoli-Warren, LLC, the ASBCA dismissed appeals because no underlying claims had been presented to the Contracting Officer. The Board rejected the appellant's suggestion that its complaint could constitute the claim. 

In Bear Mountain Cutters, Inc., the CBCA denied the Government's motion to dismiss (for lack of jurisdiction) a claim for damages to the contractor's equipment due to allegedly negligent orders from contracting officials because the claim was based on a contract clause that allocated risks between the parties, setting forth performance obligations as a result of a contractual undertaking, and, therefore, was not a claim arising solely in tort. 

In Trinity Source Logistics LLC, the ASBCA dismissed an appeal because the appellant failed to establish that it had been assigned any money due under the contract (including the appellant's claim) by the identically named contractor with which the Government had originally contracted.

In GC Columbia, LLC, the CBCA dismissed an appeal because the contractor failed to comply with lease provisions requiring it to submit evidence of tax adjustment payments within a stated amount of time. 

In Contrack Watts-Uejo Kogyo JV, the ASBCA dismissed the appeals by joint venture because the individual submitting the claim, authorizing the appeals, and retaining counsel, lacked authority to do so for the joint venture. 

In Ace Electronics Defense Systems, the ASBCA dismissed an appeal for failure to state a claim because the fixed-price contract did not provide any mechanism for raising the price after the contractor's vendor prices allegedly increased due to COVID. 

In The Heirs of Bahawouddin, Son of Neyaz Mohammad, the CBCA denied the Government's motion to dismiss for lack of jurisdiction because: (i) the claim properly was brought by parties in privity with the Government; (ii) the individual certifying the claim had the authority to do so; and (iii) the assertion in the claim that the Government owed the payment of rent at "$10,000 per month from March 1, 2017, until paid" satisfied the CDA requirement for a sum certain.

In Relyant Global LLC, the ASBCA dismissed a count alleging unjust enrichment on an implied-in-fact contract theory because there was an express contract. 

In Nassar Group International N.G.I. S.A.L. (OffShore) R.C., doing business as NGI Afghanistan for Contracting, in addition to denying the Government’s motion to dismiss these appeals on the grounds that the original named appellant was not the real party in interest and granting the contractor's cross-motion to amend the caption, the ASBCA held that: (i) the contractor's constructive suspension claim should be denied because (a) the issuance of Customs Clearance Requests (CCRs) for tax exempt status was a sovereign act and (b) the contractor failed to prove either that the time required for issuance of the CCRs was unreasonable or that its delays were attributable to the time required to obtain the CCRs; (ii) the Board lacked jurisdiction over the contractor's claim  that the Government delayed the project by mandating site-access for government personnel because that claim had not previously been presented to the Contracting Officer and, in any event, the claim had been waived by the contractor's failure to present any evidence in support of it; and (iii) the Government failed (for lack of evidence) to establish its claim that the contractor had failed to install insulated grounding conductors separate from the electrical system neutral conductor in all feeder and branch circuit raceways.  

In Selevive Group, LLC, the ASBCA held that a submission seeking compensation based on unforeseen circumstances following months of disagreement was a claim, but then the Board dismissed both (i) allegations of an implied-in-law contract based on promissory estoppel for lack of jurisdiction and (ii) the portion of the appeal related to an alleged lack of access to the site because it had not been presented to the Contracting Officer in the claim. 

In MINACT, Inc., the CBCA dismissed an appeal filed 92 days after receipt of the Contracting Officer's decision as untimely. 

In U. S. Army Tactical Supply, the CBCA dismissed an appeal as an improper attempt to relitigate a case already decided by the CBCA in a previous appeal. 

In Fluor Intercontinental, Inc., the ASBCA denied the Government's motion to dismiss a claim for certain subcontractor convenience termination settlement costs because, even though FAR Part 49 and Part 31 cost principles applied, the prime had plausibly alleged that the applicable termination settlement cost principle regarding "settling and paying" subcontractor termination claims governed, as opposed to the direct application of a FAR Part 31 cost principle to the subcontractor's claimed costs:

Fluor counters, however, that it is not relying on the depreciation cost principle (which Blanchard merely used to estimate its costs) but the termination cost principle – FAR 31.205-42 – and the Contract’s Termination for Convenience contract clause (FAR 52.249-2) that permits recovery of costs from subcontractor settlements (app. resp. at 15-16; app. reply at 3-6). The termination cost principle states, "Subcontractor claims, including the allocable portion of the claims common to the contract and to other work of the contractor, are generally allowable." FAR 31.205-42(h). The Contract’s long-form termination for convenience clause permits Fluor to recover "[t]he cost of settling and paying termination settlement proposals under terminated subcontracts that are properly chargeable to the terminated portion of the contract . . . ." FAR 52.249-2(g)(2)(ii). "A prime seeking to recover the costs of settling with a sub under the ‘settled and paid’ clause . . . need not strictly prove the allowability, reasonableness, and allocability of all of the sub’s costs." Morrison Knudsen Corp. v. Fireman’s Fund Ins. Co., 175 F.3d 1221, 1252 (10th Cir. 1999). The FAR also states that the termination contracting officer must evaluate whether the settlement "was arrived at in good faith, is reasonable in amount, and is allocable to the terminated portion of the contract . . . ." FAR 49.108-3(c). Thus, allowability of a contractor’s costs in settling a subcontractor’s claim depends on "the reasonableness and prudence of the settlement, including the competence and good faith with which the negotiations were conducted[,] and the adequacy of the information upon which the settlement was based." Gen. Dynamics Land Sys., Inc., ASBCA No. 52283, 02-1 BCA ¶ 31,659 at 156,411.

The Board left open the question whether the claimed costs were reasonable. 

Changes/Constructive Changes/Contract Interpretation/Breach/Authority

In Griz One Firefighting, LLC, the CBCA held that: (i) evidence of multiple causative factors leading to a vehicle accident was insufficient to conclude that the Government's actions caused the damage to the contractor's equipment; (ii) a BPA that did not include a minimum quantity and did not require the appellant to accept an order was not a binding contract; (iii) although an order under the BPA that was accepted by the appellant became a binding contract, the Government did not breach it because the Government conducted an appropriate investigation of a vehicle accident and took appropriate measures to address and remedy improper actions by the contractor toward government personnel; (iv) the Government did not breach the implied duty of good faith and fair dealing by suspending performance during the course of the accident investigation; and (v) the contractor failed to establish the Government had wrongfully demobilized the contractor's crews. I

In Ieyada M. Ahrir, a decision involving lease interpretation, the CBCA denied the lessor's claim for damages to the leased property because the lease only required the lessee to restore the property to the original condition for damages were caused by the lessee, not for damages outside of its control (in this case, civil unrest that led to the lessee vacating the property.

In OWL, Inc.,  the CBCA dismissed an appeal alleging lost revenue as a result of the Government's reduction in the services it ordered during the pandemic because the Government had fulfilled its only obligation by ordering the minimum guaranteed quantity under an ID/IQ contract.   

In 1425-1429 Snyder Realty, LLC, the CBCA held that: (i) interpreting a lease amendment in the context of the lease as a whole, the amendment provided the VA with unlimited access to the basement, which was available under other lease provisions, and thus there was consideration for the $5,000 per month the VA agreed to pay for that access; (ii) the parties' multi-year course of dealing in compliance with that amendment evidenced a meeting of the minds concerning its meaning; and (iii) the Government was liable for continued rental payments after it unilaterally rescinded the amendment based upon the mistaken position that unlimited access was already provided by other lease provisions.

In Cooper/Ports America LLC, the ASBCA denied a claim for reformation based upon an alleged government misrepresentation because: (i) the Government's statement that it would "work with" the contractor on prices was not a promise to revise them; (ii) there was no misstatement of fact because the Government never stated that it could revise underbid prices on a fixed-price contract; and (iii) the contractor failed to show that the parties' intention was to agree to revise the prices. 

In JAAAT Technical Services, LLC, the ASBCA held, inter alia, that: (i) requiring the contractor to obtain a second permit after the first one was revoked was not a constructive change because the contract unambiguously required the contractor to obtain and maintain all required permits; (ii) the Government did not breach the implied duty of good faith and fair dealing by not writing to the permitting authority to challenge the permit revocation, especially where the contractor did not ask the Government to do so and even participated in the decision not to do so; (iii) the delays in the permitting process were the fault of the contractor's subcontractor, which failed to have a design professional with the required certification; and (iv) the contractor was not entitled to the costs of preparing what it labeled as an REA because the letter was actually a claim.

In ECC Int'l, LLC, the ASBCA denied both a Type I differing site condition claim (because the solicitation included clear indications that the condition might be present) and a Type II differing site condition claim (because the conditions actually encountered did not differ from conditions generally encountered in the area), but then held that the Government's acceptance of a proposal that contained the contractor's clear interpretation of solicitation ambiguity created by the Government (in part by its responses to bidders' questions) bound the Government to the contractor's interpretation that the contract did not cover soil mitigation, such that subsequently requiring it was a compensable change.  

In International Development Solutions, LLC, the CBCA denied the contractor's claims for taxes paid to the Afghanistan government because there was no evidence those taxes were paid by the contractor as opposed to its holding companies and no evidence tying those taxes to the contract at issue.

In CI-Pond Solutions JV, LLC, which involved a fixed-price construction contract under which the contractor was to design and then build a Hazardous Devices School Fuselage Training Facility using a government-supplied fuselage, (i) the contractor's claims for differing site conditions were denied by the CBCA because, inter alia, bidders were provided very little information concerning conditions at the site, and part of the design work required of the contractor was to conduct a topographic survey during the design phase to determine those conditions; and (ii) the contractor was entitled to its extra costs associated with outfitting a larger government-supplied fuselage than originally specified. 

In Purple Heart Heroes LLC, which involved contract interpretation, the CBCA held that nothing in an unambiguous lease required the Government to pay an unexplained amount listed in a lease exhibit that was not referenced in the lease itself.

In Cooper/Ports America LLC, the ASBCA denied a claim for reformation based upon an alleged government misrepresentation because: (i) the Government's statement that it would "work with" the contractor on prices was not a promise to revise them; (ii) there was no misstatement of fact because the Government never stated that it could revise underbid prices on a fixed-price contract; and (iii) the contractor failed to show that the parties' intention was to agree to revise the prices. 

In Aegis Defense Services, LLC, d/b/a GardaWorld Federal Services, which involved contract interpretation, the ASBCA held that, read as a whole, the disputed task orders plainly required a minimum number of security guards and, therefore, the count in the contractor's Complaint alleging a latent ambiguity must be denied. The Board also held, however, that the issue of whether the contractor had provided the minimum required staffing levels involved disputed questions of fact which could not be resolved by the Government's motion for summary judgment.  

In Williams Bldg. Co., the CBCA denied the contractor's motion for summary judgment because, in the Board's view, the Government's agreement in a bilateral modification to seek settlement funding to cover the contractor's breach claims did not concede the Government's liability. Following is the language in the mod. You decide. "Additional funding to settle the Breach of Contract claims will be requested when additional funds are available."

In APTIM Federal Services, LLC, the ASBCA held that the closure of a military base due to the COVID pandemic was a sovereign act that precluded recovery of the contractor's claimed costs for its lack of access to the base. Similarly, in JE Dunn Constr. Co., the ASBCA held that the requirement that all personnel (not just the contractor's) coming from further than 350 miles from the site quarantine for 14 days (due to COVID restrictions) before entering the site was a sovereign act precluding recovery. 

In ASCT Group, Inc., the ASBCA held that there was no implied-in-fact contract between a subcontractor and the Government to purchase the subcontractor's materials following the termination of the prime contract because the Contracting Officer's invitation to the sub to submit an expression of interest in selling the materials did not amount to a binding offer to purchase them, and nothing in the conditional statements in subsequent correspondence between parties constituted the Government's commitment to purchase the materials.  

In Badland Truck Sales, Inc., the CBCA denied a claim to reduce the price of a wheeled loader bought at the GSA's online auction website due to defects unknown to the buyer at the time of the sale because: (i) the buyer's claim for misdescription was not submitted within 15 days as required by the auction (and the pandemic was no excuse for that failure); (ii) the item was sold "as is";  (iii) the buyer admittedly had failed to inspect it prior to purchase despite being advised by the auction terms to do so; and (iv) whether government personnel were aware of the defects prior to the sale (as alleged by the buyer) was irrelevant because the published terms and conditions of the sale included the condition that  "gross omissions regarding the functionality of items, failures to cite major missing parts and/or restrictions with regards to usage may occur" in the auctioned items' descriptions.

In CiyaSoft Corp., the ASBCA denied the contractor's motion for summary judgment as to the meaning of the term "single-user" software license because there were material issues of fact to be decided, but held that the contractor had no duty (a) to foresee that the Government might breach such a license or (b) to take action to mitigate any damages that might result from that breach before performance of the contract had even begun. 

In Aspen Consulting, LLC, after  an earlier Board decision (denying an appeal that the Government had misdirected two payments owed to the contractor) was reversed by the CAFC, the current decision reaches the same result by holding that the Government has established the affirmative defense of payment by showing the misdirected funds, were, nevertheless, paid to the benefit of the contractor.  

In Ahtna Constr. & Primary Products Co. LLC, which is a follow-on to an earlier decision in the same appeal in which the CBCA had dismissed a differing site conditions claim, the Board now holds after a hearing that the contractor should have expected to encounter, and should have planned for, frozen soil in Alaska but failed to do so and could not, therefore, claim that the 1,000 foot work zone area limitation in the contract was a defective specification that limited the amount of frozen soil the contractor could thaw and dry out. 

In French Constr. LLC, the CBCA, inter alia, denied a construction contractor's delay claims because the contractor's expert did not identify the delayed item (or the duration of delay attributable to that item) on the critical path, but instead simply subtracted the planned duration of the job from the actual duration and identified the difference as the period of delay.

In Focused Management, Inc., the CBCA denied claims for allegedly inaccurate CPAR ratings because: (i) the contractor failed to identify any factual dispute or legal error bearing on whether a marginal rating for quality was arbitrary, capricious, or otherwise mistaken; (ii) the contractor argued only in conclusory fashion and did not cite record evidence raising genuine disputes of fact about the events to which it referred or the inaccuracies it alleged in challenging a marginal rating in schedule; (iii) two short paragraphs citing no evidence were inadequate to prove the contractor's allegation that a marginal rating in management failed to account for the COVID-19 pandemic; and (iv) the contractor did not deserve more than a  satisfactory rating in cost control because the savings the contractor alleged it had achieved were largely due its inadequate staffing.

In Caring Hands Health Equipment & Supplies, LLC, the CBCA granted the Government's motion for summary judgment that one group of contracts were, by their plain language, IDIQ contracts, which the Government had fulfilled by ordering the minimum quantities, and another group of contracts were illusory because they did not contain any language identifying them as either requirements contracts or IDIQ contracts or requiring the Government to order any specific quantity, and thus the Government was obligated only to pay for quantities it actually had ordered.  

In Fluor Federal Solutions, Inc., the ASBCA held that the Government did not have the right to extend performance pursuant to FAR 52.217-8 ("Option to Extend Services") after the contractor had performed the final option year under protest, successfully arguing that the option year exercise had been ineffective.

In Pacific Dredge & Constr. LLC, the ASBCA held that FAR 52.222-30 unambiguously notified offerors that the Contracting Officer would make no adjustment (i.e., the “NONE” method) in the contract price to cover any increases or decreases in wages and benefits due to a DOL wage determination applicable at the exercise of an option that extended the term of the contract so offerors were to propose separate prices for option periods based on their own estimates of increases in wage rates, and the "Changes" clause cannot be read as providing an independent basis for adjusting wage rates in this situation.  

In Dawson Technical, LLC, the ASBCA refused to find an accord and satisfaction based upon an email exchange that nowhere included a signed bilateral contract modification.

In ACC Constr. Co., the ASBCA denied all of the contractor's numerous theories of recovery (superior knowledge, constructive change, breach of the duty of good faith and fair dealing, and differing site condition) in its claim for the costs of complying with Virginia's stormwater permitting requirements because the "Permits and Responsibilities" clause and other contract provisions placed responsibility on the contractor for obtaining and complying with those permits.  

In Finmarc Management, Inc., the CBCA held that the current lessor could not recover for the cost of removing tenant improvements on the basis of a prior lease to which it was not a party, and its current lease did not contain a provision requiring the GSA to pay for such removals.

In Trade West Constr., Inc., which involved to a large extent a battle of the experts as to the correct interpretation of contract terms, the ASBCA held that the stone proposed by the contractor (i) was not "angular" in shape as that term was generally used in the industry, (ii) was not of "varying sizes and shapes," and (iii) did not meet the contract's mass and interlock requirements. The Board also held that the contractor's use of the stone in other districts on other projects did not establish it was appropriate in this case.

In WSP USA Solutions, Inc., a decision involving contract interpretation, the ASBCA denied the appeal because the contract clearly required orders to be paid for at the rates in effect at the time the orders were issued even if the work was performed in a later contract period.

In Phylway Construction, LLC, the ASBCA held that: (i) since the fixed-price contract expressly allocated the risk of high river levels to the contractor, it could not recover under theories of commercial impracticability or constructive suspension of work; and (ii) in any event, the contractor had released those claims in bilateral mods that extended the time of performance.  

In Nassar Group International N.G.I. S.A.L. (OffShore) R.C., doing business as NGI Afghanistan for Contracting, in addition to denying the Government’s motion to dismiss these appeals on the grounds that the original named appellant was not the real party in interest and granting the contractor's cross-motion to amend the caption, the ASBCA held that: (i) the contractor's constructive suspension claim should be denied because (a) the issuance of Customs Clearance Requests (CCRs) for tax exempt status was a sovereign act and (b) the contractor failed to prove either that the time required for issuance of the CCRs was unreasonable or that its delays were attributable to the time required to obtain the CCRs; (ii) the Board lacked jurisdiction over the contractor's claim  that the Government delayed the project by mandating site-access for government personnel because that claim had not previously been presented to the Contracting Officer and, in any event, the claim had been waived by the contractor's failure to present any evidence in support of it; and (iii) the Government failed (for lack of evidence) to establish its claim that the contractor had failed to install insulated grounding conductors separate from the electrical system neutral conductor in all feeder and branch circuit raceways.  

In CES Mall, LLC, et al., the CBCA granted the consolidated appellants' motions for summary judgment because a Transportation Tax and a Sanitary District Tax were reimbursable real estate taxes under the Tax Adjustment clause in the leases involved in the dispute.  

In David Boland, Inc., the ASBCA denied the contractor's constructive change claim for providing telecommunications systems to temporary swing space trailers because the applicable TOs unambiguously required it.  

In Jemison & Partners, Inc., the ASBCA denied the contractor's appeal because the contract unambiguously provided that the contractor would be paid only for the actual quantities of topsoil placed, and not a set lump sum  payment as the contractor contended.

In FlightSafety International, Inc., the ASBCA held that, despite some arguably contradictory language in paragraph (b) of the "Validation of Restrictive Markings on Technical Data" clause (DFARS 252.227-7037), the fact that a commercial item was developed at private expense does not end the inquiry as to whether a contractor's restrictive proprietary markings on commercial technical data are valid.  

In Grand Strategy, LLC, the CBCA held that the contract's "Order Limitations" clause unambiguously relieved the Government of any obligation to order towels from the contractor when the size of order exceeded the maximum order limit in the clause.

The ASBCA sustained an appeal by KiewitPhelps because: (i) the agency's master specification was a design specification; (ii) the specification was defective because following it resulted in mold growth; (iii) the defective specification was not patent; (iv) nothing in the contractor's conduct caused the mold; and (v) the Government constructively changed the contract by mandating a change in a product in response to the mold problem. The Board also, held, however, that agency did not breach its duty of good faith and fair dealing in responding to the mold issue.

The ASBCA denied an appeal by Wright Brothers, the Building Co. mainly because: (i) the appellant failed to establish that delays allegedly attributable to the Government affected the critical path; (ii) mere delay without a change to the essential nature of the construction project did not constitute a cardinal change; and (iii) assertions of delay without proof of an affect on the critical path did not amount to a constructive change.    

Terminations/Liquidated Damages/Government Claims

In ORSA Technologies, LLC, the CBCA upheld a termination for cause because after the contractor was unable to deliver the originally-required gloves and agency had agreed to the delivery of substitute gloves, the contractor failed to deliver those gloves either.

In another ORSA Technologies, LLC, case, the CBCA upheld a termination for default for failure to deliver any of the contract items by the due date because the unavailability of the items due to the pandemic was foreseeable to the contractor before award, and the contractor had bid to deliver items that were "on hand" when, in fact, it did not have any items on hand but would have to try to procure them after award. 

In Meld, LLC, the CBCA denied the the GSA's motion for partial summary judgment upholding the termination of a lease because the record was insufficient to conclude whether the lease was continuing at the time the agency purported to terminate it. 

In Central Co., the ASBCA upheld a default termination because the contractor had not completed any work by the date it was supposed to be finished, and its vague references to problems related to COVID were not sufficient excuses because they did not establish causation, i.e., that COVID had impeded its work sufficiently to cause the default. 

In CTA I LLC, following the termination for convenience of a fixed-price construction contract, the CBCA determined entitlement to various normal pre-termination costs and also various claims of equitable adjustment for changes and delays, which, to the extent they were proven, increased the contract's price, i.e., the normal cap on convenience termination costs. 

In Zahra Rose Constr., the ASBCA held that in a convenience termination after two weeks of two-month contract, the contractor:  (i) could recover the full lease cost of trucks for which it had prepaid for the full term despite the Government's allegation that the trucks were nonconforming because the deficiencies were never communicated to the contractor nor used as a basis for rejecting the trucks or terminating the contract for default; but (ii) could not also recover additional amounts under a percentage-of-completion theory because, inter alia, the contractor's incurred costs were almost entirely redundant of any percentage-of-completion argument the contractor could make. 

In Angela Pugliese, the PSBCA denied an appeal from the termination of a mail route for default because the termination was based upon the same facts that led to the contractor's criminal conviction for obstructing the mail (by failing to deliver it), and, therefore, the criminal conviction served as res judicata. 

In Metro Machine dba General Dynamics NASSCO-Norfolk, which involved a dispute over the propriety of an assessment of liquidated damages for late completion, the ASBCA: (i) rejected the Government's accord and satisfaction defense because the Government was the only party that had signed the mod in question; (ii) held that the completion date established by the same mod was, nevertheless, reasonable especially where the contractor had failed to timely object to the terms of the mod; and (iii) found the contractor responsible for its subcontractor's delays, because the contract did not shift the responsibility for those delays to the Government. 

In Heroes Hire LLC, the CBCA: (i) denied a challenge to a default termination because the contractor had no justifiable basis for refusing to continue work under its contract unless the agency agreed to ignore the payment assignment in which the lender held a security interest; and (ii) held it lacked jurisdiction over the contractor's monetary claims because they had not been submitted to the Contracting Officer for a decision or appealed to the Board from a deemed denial. 

In Doubleshot, Inc., the ASBCA granted the contractor's motion for summary judgment to the extent it involved a government claim based on missing time cards because the Board's exhaustive review of the various applicable retention regulations and the dates established by them under the facts of this case showed that the Government's audit which gave rise to the claim was not held until after the contractor's duty to retain the time cards had expired. 

In SupplyCore, Inc., which involved a commercial items contract with fixed-prices for, inter alia, items identified to be supplied by a specific subcontractor, the ASBCA held that: (i) a disagreement between the prime and the sub on pricing did not excuse the prime's failure to deliver on time; (ii) the Board lacked jurisdiction over a count in the Complaint alleging excusable delay because a claim for a time extension had not been submitted to the Contracting Officer; (iii) similarly, a claim for defective specifications should be dismissed without prejudice because  it had not been previously presented to the Contracting Officer; (iv) the Board had jurisdiction over a claim for the Government's alleged breach of the implied duty of good faith and fair dealing raised solely as a defense to Government's default termination claim, but the Board deferred ruling on its merits until the record was more fully developed; (v) the contractor failed to prove it was misled by the Contracting Officer's email into thinking the Government was waiving the contractor's obligations with respect to requirements previously the subject of a cure notice when the email clearly identified the requirements to which it did refer; and (vi) the contractor failed to show why it should have been terminated for convenience rather than for cause after it failed to deliver.  

In Heartland Energy Partners LLC, the ASBCA held that where the contract specialist (without authority) had ordered the contractor to stop work on certain CLINs and the contractor had complied even though the Contracting Officer did not ratify the specialist's directive (but instead tried to negotiate a de-scoped effort), the actions of the Government amounted to a constructive termination for convenience of the affected CLINs, which converted the fixed price CLINs into cost reimbursable CLINs for work performed prior to the termination. 

In Gerald E. Paulus, Jr., the CBCA sustained a termination for cause of a personal services contract based on the agency's findings of legitimate bases for a co-worker's allegations of harassment and held that the contractor was on notice of the grounds for termination even though not all of them were spelled out in the termination decision. Subsequently, the Board denied the contractor's motion for reconsideration.

In Goodloe Marine, Inc., the ASBCA granted the Government's motion for summary judgment upholding a termination for default, holding that: (i) the contractor did not meet the contract's requirement for a specified amount of dredging per month and was not excused by unusually severe weather because its dredging machine's constant breakdowns were the cause, and the contractor also failed to prove that the weather was unusually severe; (ii) the Contracting Officer complied with the FAR requirements in considering the factors for, and making, the termination decision; and (iii)  there was no breach of the implied duty of good faith and fair dealing or bad faith by the Government:

Goodloe suggests it is the victim of the contracting officer’s bad faith because it was terminated and replaced by a contractor whose services could not be obtained until after Goodloe might have finished the job had it been retained. The undisputed facts belie that contention. Goodloe represented to the government that it would use a dredge that it knew was unavailable to perform its contractual obligations, then failed to perform as required without an excuse, blaming its deficiencies upon unusual weather without evidence. Against this backdrop, Goodloe’s suggestion that it was an abuse of discretion not to allow it to dredge to completion anyway, after the contract completion date expired, and at a rate of its own choosing below the contract’s 360,000 cubic yard per month mandate, is unfounded. 

Costs / CAS

In Cellular Materials Int'l, Inc., the ASBCA held that the Government had properly disallowed claimed costs for demand notes long held, but never presented for payment, by company's largest stockholder for consultant work since they were forecasted costs rather than incurred costs because the company's obligation to pay will not attach until he presents the notes for payment.  

In Strategic Technology Institute, Inc., even though the evidence showed that the contractor had timely prepared incurred cost proposals (ICPs) for its first two contract years, the contractor failed to prove that it had timely submitted those ICPs to the Government, and, therefore, the ASBCA held that the Government's claims for unallowable costs for those years (which the DCAA had discovered only after seeing references to those earlier ICPs in an ICP for a subsequent year) were not time-barred. The Board then held that the Government had proved its claim. 

In Active Constr., Inc., which involved a delay claim on a construction contract, the CBCA held that the contractor, who had consistently allocated field office costs as indirect costs throughout contract performance, was now precluded as a matter of law from recovering extended field office overhead as a direct cost.  Similarly, in In Pave-Tech Inc. , the ASBCA held that the contractor was not entitled to recover claimed field office overhead costs using a per diem rate method because that method deviated from its prior usage of a percentage cost basis in contravention of the Board's prior holding in M.A. Mortenson Co., ASBCA No. 40750 et al., 98-1 BCA ¶ 29,658 at 146,946.

In Mission Support Alliance, LLC, the CBCA: (i) denied the contractor's motion that the agency's claims were barred by the six-year limitations period because the grounds for those claims were not reasonably knowable to the agency until shortly before it filed them; and (ii) denied the contractor's appeal on the merits because the contractor had failed to provide adequate documentation to establish the reasonableness of claimed subcontractor costs. Subsequently, the Board denied the contractor's motion for reconsideration.

In Wu & Assocs., the CBCA held that: (i) it lacked jurisdiction over the part of the appeal seeking the return of a retainer fee because it was not first presented to the Contracting Officer for a decision; (ii) the contractor was entitled to its incurred costs of engineering analyses it had ordered to address defective specifications; (iii) the contractor was not entitled to the recovery of the costs of its site supervisor because it did not produce the supporting time sheet until 16 months after discovery had closed; (iv) the contractor could not recover its President's or site manager's costs allegedly associated with dealing with defective specs because those types of costs are generally included in overhead, were not separately tracked by the contractor even after it was aware of a potential claim, and were not supported by any documentation. 

Quantum 

In CTA I, LLC, the CBCA held that interest on equitable adjustment claims is not extinguished by a convenience termination.

In Lockheed Martin Aeronautics Co., which involved multiple motions for summary judgment on various preliminary matters that did not reach the merits of the contractor's claim for extra work and costs, the ASBCA held that the measured mile approach to calculating damages is not disfavored and does not require a preliminary showing of an inability to provide direct proof. The ASBCA also denied various government motions challenging jurisdiction and allegedly defective elements of the claim and granted the contractor's motions for summary judgment that, properly interpreted, no contract modifications released or barred its claim.  

Discovery/Procedure/Motion Practice

In Team Systems Int'l LLC, a decision involving contract interpretation, the CBCA denied cross motions for summary judgment because, reading the contract as a whole, after Government had reduced the quantities, there must be proof, inter alia,  as to whether, and to what extent, the contractor actually incurred restocking fees. 

In Active Constr., Inc., the CBCA denied the contractor's motion to compel mediation; ADR may be had at the Board only by mutual agreement of the parties. 

In United Facility Services Corp. dba Eastco Building Services, the CBCA dismissed for an appeal for failure to prosecute because the small business contractor failed to respond to the Government's second set of interrogatories and to the Board's orders regarding those interrogatories despite numerous time extensions, the effects of the pandemic being insufficient to excuse the extent of the delays. Subsequently, the Board denied the contractor's motion for reconsideration.

Similarly, in Brandon Staffing Solutions LLC, the CBCA dismissed an appeal for failure to prosecute because the contractor "repeatedly failed to respond to the Board’s orders in spite of having been afforded ample opportunity to do so." Also, in Ray's Electric and General Contracting, Inc., the CBCA dismissed an appeal for failure to prosecute after the contractor failed to respond to multiple Board orders.

Moreover, the ASBCA dismissed a pro se appeal by Sundance Constr., LLC, for failure to prosecute after the appellant ignored two orders by the Board giving it a chance to explain its failures to proceed with the appeal. In Najmaa Alshimal Co., the ASBCA dismissed an appeal after the appellant stated it would not respond to further board orders and wished to withdraw.  In Clean4you, the ASBCA dismissed an appeal for failure to prosecute after the appellant failed to respond to multiple board orders.

In Active Constr., Inc., which involved a discovery dispute, the CBCA granted the majority of the contractor's requests for documents the agency had withheld under the deliberative process privilege because most of disputed documents: (i) were not "pre"decisional; (ii) had no relationship to any decision the agency was contemplating; or (iii) related solely to contract administration under the disputed contract, specifically to responding to contractor's request for the change now under appeal. 

In Pranam Global Tech, Inc., after two law firms had withdrawn their appearances on behalf of the contractor and the contractor's owner had not responded to several orders from the Board, the ASBCA dismissed the appeal for failure to enter a notice of appearance by a representative meeting the requirements of Board Rule 15(a).  Similarly, in Al Sajara Al Muthmerah Co., the ASBCA dismissed an appeal by the contractor's "manager" for failure to enter a notice of appearance by a representative meeting the requirements of Rule 15(a).

In Sauer, Inc., after an earlier decision limiting the Government's ability to recover liquidated damages, which the ASBCA had affirmed on reconsideration, the Board (i) denied the contractor's motion for leave to file the affirmative defense that the Government’s liquidated damages rate was unreasonable and/or unenforceable to the extent that it challenged the specific government rate set forth in the task order, as the Board lacked jurisdiction to consider a challenge to the amount of the daily rate itself, or the manner in which that rate was set, but (ii) granted the motion to the extent that it challenged as unenforceable, the Government’s failure to apportion the liquidated damages rate based upon the contractor's completion of Phases I and II of the project. The Board also granted the contractor's motion for leave to file the affirmative defenses (a) that liquidated damages should be apportioned if not remitted entirely, and (b) that the Government had failed to state a claim upon which relief could be granted.

In Vectrus Systems Corp., the ASBCA denied cross-motions for summary judgment because material issues of fact remained concerning the interpretation of an ambiguity in the contract.

In Cascade Designs, Inc., the ASBCA denied the parties' motions for summary judgment because:  (i) the interpretation of a disputed contract term remained a material issue of fact that would require the introduction of extrinsic evidence; and (ii) the propriety of a default termination based upon alleged deficiencies identified in the cure notice raised material issues of fact, which would  require the Board to make factual findings regarding the sufficiency of contractor's response to the cure notice.  

In Forney Enterprises, Inc., the ASBCA denied the Government's motion to dismiss for failure to prosecute because the contractor had responded to the Board's Show Cause order by enumerating a list of circumstances that established its failure was not due to bad faith or contumaciousness.

In Construction Services Group, Inc., the CBCA denied the contractor's petition to require the Government to provide a decision on a claim by a date certain because the claim already had been deemed denied. 

The ASBCA denied a motion for summary judgment by pro se litigant GLJ, Inc. because the record was inadequate to sustain a finding that actions by the Government caused a reduction in contractor's crop production. 

In D&J Machinery, Inc., the ASBCA denied the contractor's motion for summary judgment because the contract was ambiguous as to whether the specifications at issue were design specs or performance specs. 

In Tanik Constr. Co., the ASBCA denied the Government's motion for summary judgment because the contractor's three affidavits created an issue as to whether the contractor was told by the Government that it could still present its claim after signing a release. 

In Safaa Al-Rawaby Co., the ASBCA exercised the Board's discretion to reinstate an appeal originally dismissed due to the appellant's repeated failures to comply with the Board's orders to show that  the contractor was represented by a person meeting the requirements of Board Rule 15(a). The Board noted that the Government did not oppose reinstatement, and the email the Board was treating a motion for reinstatement was received only three days after the original notice of dismissal and was signed by a person who subsequently established that he complied with Rule 15(a). 

In ANHAM FZCO, the ASBCA directed the Contracting Officer to issue a decision by a date certain in 2022 because the Contracting Officer's proposed date in spring 2023 was unreasonable in the circumstances and could not be justified by the Contracting Officer's upcoming extended leave or staffing issues and workload. 

In 4K Global-ACC Joint Venture, LLC, the CBCA permitted the Government to withdraw three previous responses to requests for admissions long after they had been submitted because the withdrawal met the requirements of a two-pronged test: (i) it would promote the presentation of the merits of the action; and (ii) it would not prejudice the contractor in the presentation of its case 

In Quality Trust, Inc., the ASBCA, inter alia, denied the pro se contractor's motion for a default judgment against the Government because, contrary to the contractor's contentions, Government had properly responded to  the Board's order requiring status reports concerning settlement discussions.

In Alares Constr., Inc., the CBCA denied: (i) a motion to file a claim addendum actually raising a new claim not previously the subject of a Contracting Officer's decision; (ii) a motion to compel discovery related to this new claim; and (iii) a motion to stay proceedings  pending issuance of a Contracting Officer's decision on the new claim.

In Team Systems International LLC, the CBCA granted the Government's motion to exclude three expert reports submitted by the contractor because they were extrinsic evidence essentially arguing with an earlier decision by the Board in the same appeal, which could have been offered before that decision and, in any event, which would not have changed it.

In Rita R. Wadel Revocable Living Trust and 229 Jebavy Road, LLC dba Ludington Industries Building, the CBCA denied the Government's motion to compel production of documents despite claims of privilege because:  (i) a trustee had a reasonable expectation of privacy for email messages sent by the trustee's counsel to the trustee's work email address, preserving the attorney-client privilege; (ii) the trust beneficiaries were the holders of the attorney-client privilege and could maintain that privilege for messages sent by the trustee to them; and (iii) the trust could assert the protection of the work product doctrine for both messages sent to the trustee's work email address and messages sent to the trust beneficiaries.  

In Herron Assocs., Inc., the ASBCA denied the Government's motion to dismiss the Complaint for failure to give the Government adequate notice of the basis of the claim because the contractor had included sufficient information in the Complaint: 

It has identified a cost reimbursement contract between it and the government. It has alleged that the government directed its subcontractor to provide performance which the government said it would fund under that contract. It alleges that, given the additional work, it has not been paid all of the costs of its performance and therefore seeks that additional amount. 

EAJA/Prompt Payment Act

In Prime Tech Constr. LLC, the CBCA denied an EAJA application because the applicant was not a prevailing party, had not been represented by an attorney, and had not presented expert testimony.

In Alderman Bldg. Co., the ASBCA reduced the contractor's EAJA claim by the amount of attorneys' fees incurred after ADR was canceled because the contractor's final recovery ($34,795) was only $795 more than the settlement offer made by the Government before ADR was canceled. In Iqrar Ahmed and Partner Contracting Company Ltd., however, the Board granted the full amount of the EAJA application because the Government did not contest it.

Standbuy Distributors, Inc.,  is a two-page ASBCA opinion awarding EAJA fees with almost no explanation of any of the elements of an EAJA award other than a brief discussion of why the Government's litigation position had not been substantially justified.

In 1425-1429 Snyder Realty LLC, the CBCA granted an unopposed application for EAJA fees because it satisfied all the requirements of the statute.


Court of Federal Claims

Contract Disputes Act (CDA) / Tucker Act / Jurisdiction / Standing 

In DDS Holdings, Inc., the court granted the Government's motion to dismiss a suit for lack of jurisdiction because the plaintiff had "demonstrated neither outright privity of contract with the [G]overnment nor a valid assignment of any claims that would constitute the necessary privity." Moreover, the six months that passed after the Government's objection to jurisdiction was sufficient time to permit the real party interest "to ratify, join, or be substituted in the action" pursuant to RCFC 17(a), which had not occurred.

In Avant Assessment, LLC, the court held that: (i) under the doctrine of claim preclusion, claims that should have been, but were not, included in the convenience termination proposal originally submitted to the Contracting Officer, leading to a prior decision by the ASBCA that it lacked jurisdiction over them, must be dismissed; but (ii) the Government's motion to dismiss claims based upon UCC 2-606 must be denied because the plaintiff could not have known of those claims at the time it presented its termination settlement proposal to the Contracting Officer.

In Monterey Consultants, Inc., the court denied the Government's motion to dismiss (as untimely) a suit based on a CE unit price claim and a constructive change claim because the claims before the court largely involved different operative facts and sought different remedies than the prior claims upon which the Government's motion to dismiss was based, even though the two sets of claims involved some similarities. 

In Textron Aviation Defense LLC, the court held that a claim related to CAS 413 submitted more than six years after it accrued (i.e., when contractor's predecessor in interest knew or should have known all information necessary to file claim) was untimely because: (i) CAS 413 does not contain a mandatory pre-claim procedure that would extend the accrual date; and (ii) the contractor's CAS submission was not a routine request for payment and could have been submitted as a CDA claim at the time the claim accrued.

In Sikorsky Aircraft Corp., the court denied the Government's motion to dismiss a count in the contractor's Complaint because the Government's argument that the underlying Contracting Officer's decision did not cover B&P costs conflicted with the language of the decision, which mentioned such costs 23 times and claimed they were owed even though it did not specify an amount. The court also denied the Government's motion to dismiss other counts in the Complaint because the record was not yet sufficient to decide, inter alia,  the extent, if any, to which the Government is precluded from alleging a CAS noncompliance by entering into contracts with a contractor based on disclosed accounting practices that the Government only finds noncompliant years later as a result of delayed DCAA audits. 

In Constructora Guzman, S.A., the court held that a subcontractor failed to establish it was a third party beneficiary of a government contract because there was no evidence that by retaining a percentage of money owed to the prime (in lieu of payment and performance bonds), the Government intended to confer a direct benefit on the subcontractor or assumed responsibility to pay the subcontractor.  

In The Boeing Co., on remand from the CAFC after it reversed the Court of Federal Claims' prior decision dismissing the plaintiff's complaint, the lower court held that: (i) a claim that the plaintiff characterized as a breach of contract claim was actually a claim that FAR 30.606 violates the CAS statute (and, therefore, was illegally promulgated), which is a challenge to the validity of a regulation that must be brought in district court under the  APA; and (ii) although the CAFC held that the lower court had jurisdiction over the plaintiff's illegal exaction claim because no money-mandating statute was the required for it, the court, nevertheless, lacks "authority" to consider it because challenges to the CAS statute must be brought pursuant to the CDA. 

In Square One Armoring Services Co., the court held, inter alia, that: (i) pursuant to 28 U.S.C. § 2415(f), the Government's counterclaim to recover funds disbursed by mistake to the plaintiff was not barred by the six year limitations period because the counterclaim sought to recover improperly disbursed funds (i.e., Government's undisputed overpayment of funds to the plaintiff) and arose from the identical transactional facts as those supporting the plaintiff’s own claims; and (ii) the undisputed facts established that the Government mistakenly paid the plaintiff at the "new" contract price for armored truck services provided under the "old" contract without authorization from a government official with actual or apparent authority. 

In another Square One Armoring Services Co., decision, the court held that, for purposes of the six-year limitations period, a claim based on a constructive change order accrues when the Government instructs the contractor to perform work outside the scope of the contract, not when the contractor knows the sum certain it will seek from agency for that extra work. 

In The Boeing Co., on remand from the CAFC after it reversed the Court of Federal Claims' prior decision dismissing the plaintiff's complaint, the lower court held that: (i) a claim that the plaintiff characterized as a breach of contract claim was actually a claim that FAR 30.606 violates the CAS statute (and, therefore, was illegally promulgated), which is a challenge to the validity of a regulation that must be brought in district court under the  APA; and (ii) although the CAFC held that the lower court had jurisdiction over the plaintiff's illegal exaction claim because no money-mandating statute was the required for it, the court, nevertheless, lacks "authority" to consider it because challenges to the CAS statute must be brought pursuant to the CDA. 

In State of Ohio, the court held, inter alia, that: (i) for purpose of the six-year limitations period, the accrual suspension rule does not apply to claims of which the contractor would have been aware had it exercised a contractual right; (ii) the court lacked jurisdiction over a claim for declaratory relief; (iii) the Government breached the contract by billing the contractor for costs not within the proper definition of "joint use operation and maintenance costs" as established by a previous decision in the case; and (iv) the Government breached the implied covenant of good faith and fair dealing by failing to maintain usable records of its charges and by employing arbitrary billing practices. 

In OXY USA Inc. and CITGO Petroleum Corp., the court analyzed the requirements and application of the Anti-Assignment Act (31 U.S.C. § 3727 and 41 U.S.C. § 15) in deciding the Government's motion to dismiss portions of the claim. 

In The CENTECH Group, Inc., the court dismissed two claims for lack of jurisdiction because they involved different grounds (and sought different categories of relief) from the claims previously presented to the Contracting Officer for a decision. 

 

Changes/Breach/Contract Interpretation/Defective Specs/Authority

 In E&I Global Energy Services, Inc., the court held that: (i) the contractor did not provide convincing evidence that it had completed the work on the CLINs at issue, so the Government's failure to pay for those items was not a breach;  and (ii) the contractor was not entitled to compensation for an alleged change based on information incorporated in a solicitation amendment which the contractor had a responsibility to read before signing the contract and which it represented that it had read.

In Sunrez Corp., the court: (i) granted the Government's motion to dismiss a claim that the Government had breached the terms of an SBIR contract by failing to submit the contract items (six pallets) for certification because neither the contract (when read as a whole) nor the governing SBIR statute required the Government to do so; (ii) held that the plaintiff had failed to show any contract provision that obligated the Government to perform any of three other express "duties" the plaintiff claimed the Government had failed to perform; and (iii) denied the Government's motion to dismiss the claim that the failure to submit the pallets for certification violated the implied duty of good faith and fair dealing because there remained a "plethora" of disputed material facts .

In Phillips & Jordan, Inc., after fussing at the plaintiff for its substandard briefing, the court held that: (i) the plaintiff had failed to prove the existence of a differing site condition because (a) the contract did not represent soil conditions in way the plaintiff claimed, and (b) the plaintiff failed to prove it relied on its interpretation in bidding; (ii) the plaintiff had not proven entitlement to more compensation than was already provided in a mod for another differing site condition; (iii) the plaintiff could not rely on a modified total cost theory of damages because it did not prove either (a) that its bid was reasonable or (b) that the plaintiff was not, itself, responsible for the added costs.

In Anchorage, A Municipal Corp., the court first summarily struck the Government's arguments concerning the validity of the disputed agreements raised for the first time in post-hearing briefs (never a good idea), and in contravention of court's specific orders (even more unwise), after a seven-years-long litigation. The court then held that: (i) the clear language of the original Memorandum of Understanding ("MOU") between Anchorage and the Government concerning construction of the Port of Anchorage expansion project required the Government "to provide a complete item of construction or to provide design construction and project management services, free of defects"; (ii) a subsequent Memorandum of Agreement (MOA) "confirm[ed] [the Government's] obligation to oversee, design, and construct the Project"; (iii) the Government had breached the MOU by (a) contracting with a party that did not produce a project free of defects and then (b) failing to enforce the Government's available remedies against its contractor; and (iv) the Government had breached the MOA by settling its contractor's claims without notice to plaintiff. Subsequently, in a decision limited to quantum, the court held that the plaintiff had proved (to the dollar) all of its claimed damages in the total amount of $367,446,809, consisting of (i) impairment damages representing the reduced value of the defective property as a result of the Government's construction defects, and (ii) future damages equal to the projected cost to  remove a defective structure  attributable to the Government and to stabilize the area. 

In Marine Industrial Constr., LLC, which is notable for its thorough explanations of the requirements relating to claims of excusable delay and differing site conditions (including the evidence required to support allegations related to tardy notice of such claims, waiver or constructive notice of the claims, and superior knowledge), the court held, among many other things, that: (i) the Government waived plaintiff's failure to comply with the contract's notice provisions for certain of its delay and differing site conditions claims by failed to raise notice as a defense when denying those claims; (ii) the contractor provided insufficient evidence to support its delay claim for unusually severe weather; (iii) the contractor was not entitled to recover on its differing site conditions claim for dredging clay because the contract did not affirmatively represent that the contractor would not encounter clay in its dredging operations (and, in fact, documents readily available to the contractor noted 7% clay might be encountered), and the presence of clay would be reasonably foreseeable to the contractor; (iv) neither party was entitled to summary judgment on the differing site condition claim based on excessive debris because neither party addressed the applicable standard, i.e., how a "reasonable and prudent" contractor would have proceeded in this situation; (v) the Government withheld superior knowledge concerning the minimum pipe size required to complete the project, and the contractor was misled as a result; (vi) the Government did not withhold superior knowledge concerning log traffic; but (vii) the Government did withhold superior knowledge concerning sunken debris. 

In Nova Group/Tutor-Saliba, A Joint Venture, the court: (i) denied differing site conditions claims because (a) the contract documents did not misrepresent subsurface soil conditions and disclosed that there might be subsurface obstructions, (b) readily available information alerted contractors that certain subsurface conditions might be present, and (c) the contract required contractors to conduct investigations to precisely characterize those conditions; (ii) held that plaintiff's alternate defective specifications claim was just a recasting of its unsuccessful differing site conditions claims; and (iii) held that the Government constructively changed the contract by requiring the plaintiff to re-analyze and justify a design that the Government already had approved, which delayed critical path work involved acceleration because the Government still required the work to be completed on the original schedule. 

In T.H.R. Enterprises, Inc., the court held that a general release in a bilateral settlement agreement of "any and all claims, demands, liabilities, actions, causes of action, damages, expenses, and obligations whatsoever" was broad enough to cover all claims arising prior to the execution of the agreement, not just two claims obliquely referred to in the agreement with the prefatory language "including but not limited to. . . ." 

In Raytheon Co., which involved contract interpretation, the court held that: (i) the contractor's vendor lists were not  "technical data" under DFARS 252.227-7013(a)(15) for many reasons, including the fact that they consisted of generic descriptors of parts the contractor  had purchased, coupled with numerical identifiers, along with the identity, address, and DUNS number of the supplier or manufacturer that sold the parts, but did not include descriptions of (a) the physical, functional, or performance requirements of the parts or (b) their design, manufacture, or assembly; and, therefore, (ii) the Contracting Officer's decision directing the contractor to remove certain proprietary markings from the vendor lists  based on the erroneous assumption that they were comprised of technical data was improper. 

In Northrop Grumman Systems Corp., the court finally decided a slew of claims and counterclaims involving allegations of, inter alia, delay, disruption, and nonconforming supplies in a suit filed a decade ago, summarizing its conclusions as follows:

Ultimately, both parties suffered the foreseeable consequences of overconfidently entering into an enormous production contract before a single successful pre-production machine had been tested. That overconfidence coupled with subsequent mismanagement by the contracts and accounting administration teams on both sides had a ripple effect that led to ten years of litigation, which ends, in this court at least, without a clear win for either party. 

Basically, the Government had withheld the contract balance solely to offset its claims for delays caused by the late delivery of admittedly conforming supplies. The court, however, held that the Government was responsible for that late delivery so it should pay the contract balance. Neither party recovered much on its additional claims against the other. 

In Seneca Sawmill Co., the court held that, although the contract provision originally relied on by the Government to partially terminate a timber sales contract was inapposite because it only applied when a court order required the termination, other contract provisions permitted partial termination if continuation of the contract would cause certain environmental injuries or other adverse effects, and the contractor was not entitled to further recovery under the applicable clause because it had not proved "the rates paid for comparable timber on the same national forest" during the six-month period that preceded the partial termination were higher than the then-current contract rates.

In State of Ohio, the court held, inter alia, that: (i) for purpose of the six-year limitations period, the accrual suspension rule does not apply to claims of which the contractor would have been aware had it exercised a contractual right; (ii) the court lacked jurisdiction over a claim for declaratory relief; (iii) the Government breached the contract by billing the contractor for costs not within the proper definition of "joint use operation and maintenance costs" as established by a previous decision in the case; and (iv) the Government breached the implied covenant of good faith and fair dealing by failing to maintain usable records of its charges and by employing arbitrary billing practices.  

Previously, in Capitol Indemnity Corp., the court held, inter alia, that a surety's equitable subrogation rights had not been triggered as to most progress payments made by the Government because the surety had not asserted its rights at the time those payments were made, and the contractor was still working with the Government to resolve its problems with contract performance--so the Government did not have the required knowledge of the default under the bonds. Now, in the latest decision in the case, the court has held that: (i) the plaintiff did not take the steps necessary to trigger its right to equitable subrogation on the contractor's ninth progress payment request; and (ii) the surety cannot recover under the theory of equitable subrogation for its costs of replacing a defective gym floor installed by the contractor (leaving open the question whether there might be a CDA claim somehow available). In a separate opinion, the court sanctioned the plaintiff's counsel for continuing to allege factually inaccurate statements in its filings. 

In Supreme Foodservice GmbH, the CAFC affirmed the prior ASBCA decision and held that the Government had not waived its defense (the contractor's prior material breach) which barred the contractor's claims against Government. Without a valid underlying contractor claim, the contractor could not recover CDA interest on the Government's alleged over-withholding. 

Fraud

In Lodge Constr., Inc., which involved government claims for fraud, the court held, inter alia, that: (i) the contractor's claim was fraudulently based on operating and standby rates for a type of dump truck listed in a USACE Manual when the dump trucks the contractor actually used were worth far less; (ii) the inefficiency ratio used by the contractor in calculating its claim was fraudulent because it was not reasonable or accurate and because it captured days that were not part of the contractor's claim; and (iii) the contractor's failure to utilize  information in a contract modification while calculating its inefficiency ratio was not fraudulent because its interpretation of the mod was within the zone of reasonableness. Subsequently, the  court (i) has various motions for, inter alia, (a) reconsideration of parts of its original decision (e.g., the untimeliness of one of the Government's counterclaims in fraud) and (b) the resolution of other formerly open issues such as the possibility of additional discovery and the  status of the contractor's wrongful termination claim,  and (ii) held that all issues had been resolved or were and that the case was at an end.

Terminations

 In American Medical Equipment, Inc., the court upheld a termination for default because: (i) the contractor failed to deliver any of the contract products (nitrile gloves) by the non-extendable, contractually-required date (which had been repeatedly emphasized, and to which the contractor had repeatedly committed itself, prior to award); (ii) the contractor notified the Government prior to the required delivery date that the contractor would not meet it (which constituted anticipatory repudiation); and (iii) the contractor's default was not excused by the COVID outbreak in China allegedly delaying the manufacture of the gloves and their shipment to the United States since (a) the solicitation had called for the supply of "on-hand (or already in existence)" gloves and (b) the contractor's offer had stated the gloves would be delivered by Federal Express, not by shipment in vessels. The court cited to the CBCA's decision in ORSA Technologies, LLC, which had reached essentially the same conclusions in essentially the same situation.  Similarly, In Servant Health, LLC, et al., the court, inter alia, upheld the terminations for default of suppliers who had promised to provide specific PPE (that they represented they had on hand) within a set number of days, when, in fact, they did not have the PPE in hand and did not meet the delivery schedule.

In 27-35 Jackson Ave., LLC, the court: (i) upheld the Government's termination of a lease as untenantable (after a water leak interrupted operations and exposed important documents to water damage) because the lease included an express agreement by the parties indicating that the untenantability would be "determined by the Government"; (ii) held that the lease did not require the Government to utilize or memorialize an objective standard for determining whether the premises were tenantable following the damage; and (iii) noted that the Government's determination did not breach the implied duty of good faith and fair dealing.

In ACLR, LLC, the court granted the Government's motion for summary judgment on the limited issue whether, for purposes of calculating the amount of a termination for convenience recovery, plaintiff's system was a "standard record keeping system" as required in FAR 52.212-4(l), which the court defined as "a regularly used, carefully thought-out method that involves a set of organizing and orderly procedures." The court held that, based on the evidence of its system presented by the plaintiff, that system did not satisfy the definition. 

Discovery, Evidence, Procedure

In BES Design/Build, LLC, the court granted the Government's motion to transfer the case for consolidation with pending appeals at the CBCA because, inter alia: (i) both actions involved the same contract and shared some similar issues; (ii) the plaintiff appealed first to the CBCA; (iii) there were overlaps in the witnesses who would testify and the subjects of their testimony; and (iv) the transfer would avoid duplication of effort.

In United Communities, LLC, the court of denied the plaintiff's motion for an extension of time to file an appeal of the court's earlier decision to the CAFC because the late appeal was due solely to a mistake by the appellant's attorney, which did not amount to either excusable neglect or good cause under Federal Rule of Appellate Procedure 4(a)(5)(A).  

In Advanced Powder Solutions, Inc., the court (a) denied the plaintiff's motion to compel discovery after the plaintiff's counsel conceded it believed the Government's representation that it had already provided all responsive documents in its possession and (b) refused to sanction the Government for spoliation because: (i) the request for sanctions was made within a brief and not as a separate motion as required by the rules; (ii) the plaintiff did not cite to any requirement for the Government to retain the records during litigation; (iii) the plaintiff failed to prove the records were destroyed with a culpable state of mind; (iv) the records were originally prepared by the plaintiff, itself, and it had not retained them either; and (v) the plaintiff failed to establish the missing records would have proved its case.  

In Spectre Corp., the court decided cross motions to exclude various proffers of layperson and expert testimony, discussing at length the standards that apply to the admissibility of each.  

In David Boland, Inc., the court denied cross-motions for summary judgment as to costs of replacing allegedly defective work because of multiple factual disputes as to whether the criteria for economic waste were met.  

Court of Appeals for the Federal Circuit

Jurisdiction/Standing/Res Judicata 

In Zafer Constr.Co., the Court of Appeals for the Federal Circuit (CAFC) reversed the prior Court of Federal Claims decision (which had dismissed a suit on the basis that the underlying document did not request a Contracting Officer's final decision and, therefore, was not a claim). The CAFC reasoned that it was sufficient that the document "implicitly" requested a final decision.

In Carmazzi Global Solutions, Inc., the CAFC held it lacked jurisdiction over an untimely appeal filed with the court more than 120 days after the appellant received a copy of the CBCA's decision--its attorneys' unfamiliarity with the court's rule being no excuse.  

Changes/Breach/Contract Interpretation

 In Aspen Consulting, LLC, the CAFC reversed the prior ASBCA decision and held that the Government had breached the contract by making payments to an account other than the one listed in the CCR database, which was the account required by the "Payments" clause (FAR 52.232-33). The court remanded the case to the ASBCA to decide the Government's affirmative defense of payment, i.e., whether the contractor had benefitted from the funds paid to the wrong account.

In Lebolo-Watts Constructors 01 JV, LLC, a decision labeled as nonprecedential, the CAFC affirmed the prior ASBCA decision denying the contractor's claims because: (i) the contract was patently ambiguous as to whether the contractor was to furnish circuit breakers (even though the breakers were low cost items, they were important to the project), and the contractor had failed to inquire concerning the ambiguity prior to bidding; and (ii) the subcontractors' pass-through delay claims (a) were based on delays associated with circuit breakers, which were attributable to the contractor, not the Government, (b) were concurrent with contractor-caused delays, and/or (c) had been waived in a bilateral modification.

In CSI Aviation, Inc., the CAFC reversed the prior CBCA decision and held that, contrary to the Board's conclusion, the contract expressly incorporated the contractor's standard terms and conditions by reference. The court then remanded the case to the Board for further proceedings consistent with the court's decision.

In U.S. Aeroteam, Inc., a decision labeled as nonprecedential, the CAFC affirmed the prior CoFC decision denying the contractor's claims, holding that: (i) there was no constructive change or cardinal change because the Government had not ordered extra work but had merely approved an idea the contractor had initiated and proposed; (ii) the lower court's erroneous suggestion that the contractor must show a constructive change order authorized a change in the contract price was harmless error because there was no order at all; and (iii) there was no commercial impracticability where the contractor's supplier had merely raised the price of its parts, leading the contractor to choose a different route rather than to pay that increased price.   

Terminations

In GSC Constr., Inc., a decision labeled as nonprecedential, the CAFC affirmed the prior ASBCA decision upholding a termination for default because: (i) the Government did not breach the contract by requiring the contractor to remove and replace soil since the contract clearly required it to do so; (ii) the contractor was not entitled to a time extension due to the Government's review of drawings under a more stringent edition of a governing specification than the one the contractor had mistakenly used because the Government had advised the contractor of the correct edition to use; and (iii) the Government had not forfeited its right to enforce the project's completion date because it had specifically and repeatedly reserved its right to do so, and the contractor had missed the extended date by which Government had given it a chance to finish the work.

In Microtechnologies LLC dba MicroTech, a decision labeled as nonprecedential, the CAFC affirmed the prior CBCA decision that the contractor was not entitled to the price of a software maintenance contract for the option year following a T for C because it had purchased a three year maintenance contract at the beginning of the base year without any requirement to do so and with no assurance any options would be exercised, so the cost of the maintenance agreement did not "result" from the termination. 

In E&I Global Energy Services, Inc., the CAFC reversed the prior CoFC determination dismissing a contractor's claim for an improper default termination and held that the contractor should be allowed to try to develop its case that the failure of the sureties to pay subcontractors necessitated the contractor's efforts to do so, which excusably delayed the work. The CAFC, however, affirmed all the CoFC's other holdings, including that the contractor had not shown that the Government had breached either its implied duty of good faith and fair dealing or its obligation to disclose superior knowledge because the contractor had not shown that it was misled as to status of payments to subcontractors.  

Cost Principles


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