Springfield Parcel C, LLC v. United States
124 Fed. Cl. 163 | United States Court of Federal Claims | 2015
What This Case Means for Subcontractors
The GSA awarded a lease to Eisenhower for a TSA headquarters building, but the proposal exceeded the 625,000 square foot limit Congress had set in the appropriations bill. Springfield Parcel C challenged the award, and the court agreed—the lease was void because GSA knowingly accepted a non-compliant proposal. This case shows that government agencies must follow congressional spending limits and material contract requirements, even after selecting a contractor.
Key Takeaways
- •Government contracts must comply with all congressional appropriations conditions and limits—agencies cannot ignore them even after making an award.
- •If a winning bid violates a material term in the request for proposals or a congressional mandate, the entire contract can be voided and re-bid.
- •Subcontractors should verify that prime contractors' proposals meet all stated requirements and congressional restrictions before signing on, as a flawed award can be overturned.
GSA's action was contrary to law and the Public Buildings Act.
Frequently Asked Question
Can a government contract be cancelled if the winning bid violates a congressional spending limit?
Yes. In this case, the court voided the entire lease because the winning proposal exceeded the 625,000 square foot limit Congress imposed. Government agencies must follow all appropriations conditions and material contract terms, and courts will cancel awards that violate them.
Related Cases
Texas Natural Resource Conservation Commission v. IT-Davy
Sovereign immunity bars a contractor's breach-of-contract suit against a state agency absent express legislative consent; neither the agency's conduct, contract terms, nor general statutes waive immunity from suit.
Martin K. Eby Construction Company, Inc. v. Dallas Area Rapid Transit
A contractor must exhaust administrative remedies established by a regional transportation authority before pursuing breach of contract claims in court, even when the authority lacks governmental immunity from suit.
Edwin P. Harrison, and United States of America, Party in Interest v. Westinghouse Savannah River Company
The Fourth Circuit reversed the district court's dismissal, holding that the False Claims Act broadly reaches false statements made to obtain government contract approval, not just false payment claims themselves.
Green International, Inc. v. Solis
No-damages-for-delay clauses in construction contracts need not meet the conspicuousness requirement established in Dresser for exculpatory negligence clauses, and such clauses are enforceable to bar delay damages absent specific exceptions.
Heldenfels Bros. v. City of Corpus Christi
A municipality owes no duty to a subcontractor to ensure a general contractor provides valid payment bonds, and a subcontractor cannot recover from the municipality under quantum meruit, unjust enrichment, or negligence theories when the general contractor abandons the project.
Flameout Design & Fabrication, Inc. v. Pennzoil Caspian Corp.
Summary judgment for defendants was properly granted because Flameout failed to satisfy the statute of frauds for an alleged three-year contract, as the three documents cited did not constitute a signed, enforceable written agreement for the sale of goods.