FEDERALCourt of Appeals for the D.C. Circuit
2018

United States v. Hirani Eng'g & Land Surveying, P.C.

345 F. Supp. 3d 11Court of Appeals for the D.C. Circuit • Decided 2018Enforced

HOLDING

ACC, a subcontractor on a federal construction project in Washington D.C., sued its contractor Hirani and the surety Colonial for unpaid work totaling $2.17 million. The court ruled in ACC's favor on both the Miller Act claim against the surety and the breach of contract claim against the contractor. Colonial's counterclaims for project completion costs were rejected. This case shows that subcontractors can successfully recover from sureties when contractors fail to pay, even on federal projects.

KEY FINDINGS

Change Order

Document all work performed and costs incurred meticulously—ACC's evidence was strong enough to win a five-day bench trial and recover full damages

Termination for Convenience

Miller Act claims against sureties are viable when contractors don't pay; you don't have to rely solely on the contractor for payment

Dispute Resolution

Keep detailed records of change orders, termination issues, and contract disputes—these were key evidence in proving ACC's case

FULL COURT OPINION