FEDERALUnited States Court of Federal Claims
1997

McDonnell Douglas Corp. v. United States

37 Fed. Cl. 295United States Court of Federal Claims • Decided 1997Enforced

HOLDING

McDonnell Douglas and General Dynamics sued the Navy over an A-12 aircraft development contract terminated in 1991. The court ruled that an incrementally funded fixed-price contract's H-7 clause caps the contractor's cost recovery at only the funds the government had obligated by the termination date—not the total costs actually incurred. This means contractors cannot recover work performed beyond the amount of money the government had committed, even if the contract required that work.

KEY FINDINGS

Retention

Incrementally funded contracts limit your recovery to obligated funds at termination, not actual costs incurred—review your contract's funding clause before starting work.

Termination for Convenience

If your contract uses an H-7 or similar incremental funding clause, track the government's cumulative obligations monthly and stop work if funding falls behind your schedule.

Change Order

Termination for convenience does not override incremental funding limits—you cannot claim extra costs for work performed beyond obligated amounts, even if the government ordered it.

FULL COURT OPINION