District of Columbia v. Heman Ward, Inc.

261 A.2d 836, 1970 D.C. App. LEXIS 211
CourtDistrict of Columbia Court of Appeals
DecidedFebruary 6, 1970
Docket4759
StatusPublished
Cited by13 cases

This text of 261 A.2d 836 (District of Columbia v. Heman Ward, Inc.) is published on Counsel Stack Legal Research, covering District of Columbia Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
District of Columbia v. Heman Ward, Inc., 261 A.2d 836, 1970 D.C. App. LEXIS 211 (D.C. 1970).

Opinion

KELLY, Associate Judge.

The July, 1957 contract in which Heman Ward, Inc. (hereinafter Ward) agreed to build two bridges for the District of Columbia assessed against the contractor liquidated damages of $150 for each day that the job exceeded the completion period of 360 calendar days. During the course of construction, change orders and decisions of the contracting officer extended this completion period by 177 days. Because the actual completion date, April 10, 1959, was seventy-four days beyond the extended completion date, the contracting officer assessed liquidated damages of $11,100 against Ward.

Contending that the delay was excusable under Article 9 1 of the contract, Ward appealed under this article and Article 15, 2 *838 the disputes clause, to the District of Columbia Contract. Appeals Board (hereinafter the Board). Considering four of Ward’s six separate appeals, the Board allowed Ward an additional twelve-day time extension. The remaining two claims were dismissed without a hearing. Ward then brought a breach of contract action against the District of Columbia in the District of Columbia Court of General Sessions for the remaining $9,300 withheld as liquidated damages. The record before the Board was stipulated as the record before- the trial court and the case was considered on cross-motions for summary judgment. 3 The District of Columbia appeals from the trial court’s decision on two of Ward’s claims and from the court’s remand to the Board of the two dismissed claims.

I

Although neither party asserts the finality of the Board’s decision, the fact that we have been cited to no District of Columbia authority denying finality to a factual determination by the Board and the strong “finality” language of Article 15 4 require us to comment on the question of review.

In Kenny Construction Company v. District of Columbia, 105 U.S.App.D.C. 8, 262 F.2d 926 (1959), the United States Court of Appeals for the District of Columbia noted that the presence of the Wunderlich Act 5 prevents the District from asserting United States v. Wunderlich, 342 U.S. 98, 72 S.Ct. 154, 96 L.Ed. 113 (1951), as a bar to the finality provision in the standard disputes clause and held that the Board’s decisions were not final as to questions of law. The rationale of Kenny Construction and the availability of many decisions of the United States Supreme Court 6 construing and applying standard United States contract provisions similar to those used by the District of Columbia 7 compel us to apply the Wunderlich Act standards of judicial review. Thus the Board’s decision can be afforded no finality if it can be shown to be “fraudulent or capricious or arbitrary or so grossly erroneous as necessarily to imply bad faith, or is not supported by substantial evidence.” 8

*839 II

Ward originally claimed thirty-five days of excusable delay due to unforeseeable unusually severe weather from January 25, 1958, to March 1, 1958. The contracting officer allowed one day during the January portion of this period and eight days during February, 1958. Noting that unusually severe weather delayed the project during all of the twenty-eight days of February, 1958, but that twelve days of such weather iyas foreseeable, 9 the Board allowed Ward an additional eight days for completion. The trial court found substantial evidence to support the Board’s February determination, but, because “there was no testimony in the record before the Board regarding foreseeability of unusually severe weather on these days in January,” the court could find no substantial evidence to support the January finding and granted Ward the six January days as excusable delay.

The second excusable delay claim was for twenty-seven days that an access road, needed to haul heavy steel girders, was blocked by the excavation of another contractor under contract with the District. The trial court found that the Board’s denial of this claim was not supported by substantial evidence and awarded Ward twenty-seven days excusable delay.

The District argues that the trial court erred because both decisions of the Board were, in fact, supported by substantial evidence.

To determine whether the Board’s findings were supported by substantial evidence, we must look to the entire record, or those parts to which the parties refer us, and ascertain whether such findings could be fairly and reasonably made. United States v. Carlo Bianchi & Company, Incorporated, 373 U.S. 709, 715, 83 S.Ct. 1409, 10 L.Ed.2d 652 (1963); Universal Camera Corporation v. NLRB, 340 U.S. 474, 488, 71 S.Ct. 456, 95 L.Ed. 456 (1951); Braniff Airways, Incorporated v. CAB, 126 U.S.App.D.C. 399, 408, 379 F.2d 453, 462 (1967).

In our judgment the trial court erred in holding that the Board’s finding that the contracting officer was correct in allowing only one day excusable delay for severe weather in January, 1958, was not supported by substantial evidence. We need not comment on the Board’s finding that the January delay was never pleaded by Ward because the Board noted, and the record reflects, that a District of Columbia Highway Department engineer testified that Ward performed substantial work on all of the days in question except Saturdays and Sundays. The unquestioned testimony of the engineer, who was on site during the days in question and who testified from a diary, indicated that the work was productive and not limited to bad weather clean-up. When compared with the whole record this evidence appears to be substantial in that the Board’s decision could be reasonably and fairly made, and therefore, the Board’s finding on this point is final.

The trial court also erred in finding no substantial evidence to support the Board’s finding that the excavation of a sewer contractor did not block Ward’s access to the site for the purpose of transporting heavy steel girders. A review of the whole record reveals substantial evidence to support the finding that during the period in question only part of the available *840 access area was blocked by the sewer excavation.

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Bluebook (online)
261 A.2d 836, 1970 D.C. App. LEXIS 211, Counsel Stack Legal Research, https://law.counselstack.com/opinion/district-of-columbia-v-heman-ward-inc-dc-1970.