CB Portable Toilet Rental and Services

CourtArmed Services Board of Contract Appeals
DecidedAugust 26, 2024
Docket63449
StatusPublished

This text of CB Portable Toilet Rental and Services (CB Portable Toilet Rental and Services) is published on Counsel Stack Legal Research, covering Armed Services Board of Contract Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
CB Portable Toilet Rental and Services, (asbca 2024).

Opinion

ARMED SERVICES BOARD OF CONTRACT APPEALS Appeal of - ) ) CB Portable Toilet Rental and Services ) ASBCA No. 63449 ) Under Contract No. N00189-22-P-0368 )

APPEARANCE FOR THE APPELLANT: Mr. Chizoma B. Onyems President Auburn, CA

APPEARANCES FOR THE GOVERNMENT: Craig D. Jensen, Esq. Navy Chief Trial Attorney James P. Winthrop, Esq. Autumn W. Hazy, Esq. James Vaiden, Esq. Trial Attorneys

OPINION BY ADMINISTRATIVE JUDGE MELNICK REGARDING QUANTUM

On August 16, 2023, the Board issued its entitlement ruling in this appeal briefed at appellant’s request under Board Rule 11. CB Portable Toilet Rental Svcs, ASBCA No. 63449, 23-1 BCA ¶ 38,421. The matter arises from the termination for convenience of a contract for the delivery and maintenance of portable toilets and hand washing stations for use at Camp Lejeune, North Carolina. The entitlement decision is summarized as follows.

The government awarded the contract to CB Portable on May 27, 2022. It contained FAR 52.212-4, CONTRACT TERMS AND CONDITIONS— COMMERCIAL PRODUCTS AND COMMERCIAL SERVICES (NOV 2021). Id. at 186,711.

The contract contained five line items (CLINs) identifying five training sites. At each site two portable toilets and one hand washing station were to be located and serviced for scheduled weeks, beginning in June or July 2022, running into September with later dates contemplated. Generally, each week on a site was a contract “unit.” All five CLINs specified $1,030 as the price of a unit. The five CLINs were subject to DFARS 252.232-7007, LIMITATION OF GOVERNMENT’S OBLIGATION (APR 2014), (“LOGO” clause), which limited the government’s payment obligations to an allotted amount. Although the total price of the contract was $145,230, at the time of award, the five CLINs had only been allotted $29,870 in funding. Id. Separately, the contract required two “perpetual” portable restrooms and one hand washing station to include maintenance and cleaning service twice a month at an unidentified site. Id. Though no price was given for this requirement, the Board concluded that $1,030 per week was also reasonable. Id. at 186,715.

Finally, during performance, the parties agreed to a contract change permitting the government to order units for additional locations and times at the $1,030 price. Id. at 186,712, 186,715.

On August 12, 2022, the government terminated the contract for convenience, effective August 19, 2022. The government also added funding for the five CLINs that brought the total allotted to $32,960, which it paid to CB Portable. CB Portable completed services and stopped operations as of August 19. Id. at 186,713.

CB Portable’s appeal sought additional compensation beyond the government’s payment. The government argued that CB Portable’s recovery was strictly limited by the LOGO clause to the $32,960 it had allotted to the contract and already paid. Id. at 186,715. The Board recognized that under this commercial item contract’s termination for convenience provision CB Portable should “‘be paid a percentage of the contract price reflecting the percentage of the work performed . . . plus reasonable charges’ that CB Portable ‘can demonstrate . . . have resulted from the termination.’” Id. at 186,714. The Board noted the government’s concession that CB Portable performed the five CLINs and perpetual requirement as scheduled until the effective date of the termination. It held that the liability constraints of the LOGO clause applied only to the five CLINs but not to the perpetual requirement or the changed work. Given that the contract price for CB Portable’s performance of the five CLINs only exhausted $21,630 of the $32,960 allotted to them, CB Portable was entitled to the price of their performance. Additionally, it found CB Portable was entitled to the contract price for its performance of the perpetual provision and for units provided in response to government orders stemming from the contract change. Id. at 186,715-16.

Turning to the termination clause’s provision for “reasonable charges” resulting from the termination, the Board observed this “broadly requires payment of charges that do not relate to work completed but fairly compensate” CB Portable, including profit on some components. Id. at 186,716 (citing SWR, Inc., ASBCA No. 56708, 15-1 BCA ¶ 35,832 at 175,223). After flatly rejecting some of the categories of costs sought by CB Portable, the Board deferred for the quantum phase the determination of the total number of units provided and further consideration of fair compensation. However, it noted that to the extent these charges supported contract performance, they were subsumed within the unit prices and are not separately recoverable. Also, after accounting for the price of performance, only $11,330 remained allotted to the five CLINs. The LOGO clause limited further compensation associated solely with

2 the CLINs to that amount. Charges pertaining to the perpetual provision and changed work were not so constrained. Id.

Having completed additional briefing under Board Rule 11, the parties now return for a quantum ruling. 1

FINDINGS OF FACT

CB Portable performed the five CLINs and perpetual work through the effective date of termination. It has been paid for those tasks. Id. at 186,713-15.

The government concedes it requested and received from CB Portable additional services discussed in the entitlement decision resulting in CB Portable providing five more units beyond those specified in the contract, at $1,030 each, for a total of $5,150 (gov’t br. at 13-15). CB Portable, 23-1 BCA ¶ 38,421 at 186,712. CB Portable has failed to prove the government ordered any other services.

CB Portable needed six physical units (each consisting of two portable toilets and one handwashing station) to perform the successive scheduled work for the five CLINs, and separate “perpetual” requirement. Only one more physical unit was necessary to perform the additional changed work because no more than one was ever scheduled for any particular date. Id. at 186,711-12. Hence the total number of physical units required to perform was seven. CB Portable had four units already located at Camp LeJeune before it commenced performance. Its evidence shows that it shipped a quantity of 48 to Camp Lejeune, at a cost of $16,997.86, though it is not clear whether that was units or individual pieces of equipment. If the latter, that would be 16 physical units. (App. supp. R4, tab 16; app. supp R4, ex. 14) Giving the benefit of the doubt to CB Portable that it shipped 16 physical units, that breaks down to approximately $1,062.37 per physical unit, as opposed to $354.12 per physical unit if it shipped 48. It has failed to establish why it shipped so much equipment. Given the totality of the circumstances, we hold it was reasonable to have 10 physical units available to address government contingencies and unforeseen events, meaning six needed to be shipped. At $1,062.37 per unit, that totals $6,374.22. However, that figure is likely too low given that shipping costs per unit can generally be expected to

1 On July 5, 2024, CB Portable filed a cryptic notice that could be construed as withdrawing its appeal. After the Board issued an order seeking clarification, CB Portable responded on July 13, 2024, that it was not withdrawing its appeal. Accordingly, we take no action on the request. After the Board decided entitlement and after quantum briefing was completed, CB Portable filed a document on July 10, 2024, purporting to assert superior knowledge as a theory of recovery. We disregard that filing as an untimely attempt to reopen review of entitlement. 3 drop with volume. Accounting for the fact that we have reduced the number of physical units that had to be transported, we find a fair total shipping charge that CB Portable could have expected for the six units is $10,000.

DECISION

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CB Portable Toilet Rental and Services, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cb-portable-toilet-rental-and-services-asbca-2024.