FEDERALUnited States Court of Federal Claims
2015

Springfield Parcel C, LLC v. United States

124 Fed. Cl. 163United States Court of Federal Claims • Decided 2015Voided

HOLDING

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 FINDINGS

Retention

Government contracts must comply with all congressional appropriations conditions and limits—agencies cannot ignore them even after making an award.

Change Order

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.

FULL COURT OPINION