United States of America, for the use of WCA Construction, LLC v. C.A.R.P.I., USA, INC. and Federal Insurance Company

CourtDistrict Court, D. New Mexico
DecidedMay 12, 2026
Docket1:25-cv-00885
StatusUnknown

This text of United States of America, for the use of WCA Construction, LLC v. C.A.R.P.I., USA, INC. and Federal Insurance Company (United States of America, for the use of WCA Construction, LLC v. C.A.R.P.I., USA, INC. and Federal Insurance Company) is published on Counsel Stack Legal Research, covering District Court, D. New Mexico primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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United States of America, for the use of WCA Construction, LLC v. C.A.R.P.I., USA, INC. and Federal Insurance Company, (D.N.M. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW MEXICO

UNITED STATES OF AMERICA, for the use of WCA CONSTRUCTION, LLC,

Plaintiff, v. 2:25-cv-00885-DHU-GBW C.A.R.P.I., USA, INC. and FEDERAL INSURANCE COMPANY,

Defendants.

MEMORANDUM OPINION AND ORDER THIS MATTER comes before the Court upon Defendants C.A.R.P.I, USA, Inc. (“CARPI”) and Federal Insurance Company’s (“Federal”) (collectively “Defendants”) Motion to Dismiss, or Alternatively, to Stay Plaintiff WCA Construction, LLC’s (“WCA”) Complaint. Doc. 12. Having considered the parties’ briefs and the applicable law, the Court denies Defendants’ motion to dismiss and grants their motion to stay. I. BACKGROUND This action concerns WCA’s recovery under a payment bond brought pursuant to the Miller Act, 40 U.S.C. § 3131, et seq. Disputes have arisen between the parties involved in a construction project located at the El Vado Dam about 160 miles north of Albuquerque, New Mexico. The Miller Act requires recipients of certain government construction projects to obtain a performance bond and a payment bond. The Act allows suppliers of labor and materials to bring civil actions on the payment bond for any amount unpaid after they complete their contractual obligations. 40 U.S.C. § 3133(b)(1); see U.S. ex rel. A & R Supply of Mississippi v. Travelers Cas. & Sur. Co. of America, 265 Fed.Appx. 236, 238, 2008 WL 345529, 2 (5th Cir. 2008). The Act's purpose is to “protect those who furnish labor and material for public construction and to insure that they will be paid for the same.” Graybar Elec. Co. v. John A. Volpe Constr. Co., 387 F.2d 55, 58 (5th Cir. 1967) (quoting St. Paul-Mercury Indem. Co. v. United States for Use of H.C. Jones, 238 F.2d 917, 921 (10th Cir. 1957)). CARPI entered into Prime Contract Number 140R4020C0002 (the “Prime Contract”) with the U.S. Bureau of Reclamation (the “Bureau”) to construct the El Vado Seepage Reduction

Modification to Dam (the “Project”).”1 Doc. 1 at ¶ 8; Doc. 13 at 3. Pursuant to 40 U.S.C. § 3131, CARPI, as principal, and Federal, as surety, executed a bond for the prompt payment of all persons supplying labor and materials used in carrying out the Project. Id. at ¶ 9. In connection with CARPI’s performance of the Prime Contract, in February 2022, CARPI entered into a subcontract agreement (the “Subcontract”) with WCA, whereby WCA agreed to perform various earthwork and concrete work on the Project. Id. at ¶ 10. Under the Subcontract’s disputes provision, WCA agreed to be bound “to [CARPI] to the same extent that [CARPI] is bound to [the Bureau] by the terms of the Prime Contract and by any decision or determination made by [the Bureau], [the Bureau’s] representative, board, court, arbitration panel, or other

tribunal to the extent that the work of [WCA] is involved.” Id. at 38. WCA also agreed that if it filed a Miller Act suit against CARPI, Federal, or both, it must, “upon [CARPI’s] good faith request, consent to a stay of such suit or action pending the exhaustion of the procedures for the resolution of disputes under the Prime Contract.” Id. The Subcontract clarified that WCA’s compliance with this process “shall not be deemed to be a waiver of its Miller Act rights.” Id. at 39.

1 The Prime Contract is not in the record. On May 17, 2024, the Bureau terminated the Prime Contract for its convenience.2 Doc. 13 at 4. On May 22, 2024, CARPI provided WCA with notice of the Bureau’s termination of the Prime Contract. Id. at 5. On May 1, 2025, CARPI submitted a termination settlement proposal to the Bureau, which included the “contract closeout termination proposal” that WCA submitted to CARPI on June 24, 2024.3 Id. CARPI’s termination settlement proposal remains pending with the

Bureau. Id. The Complaint alleges that CARPI and Federal have failed to pay WCA in full for the work provided pursuant to the Subcontract. Specifically, WCA alleges that it is owed at least $1,279,398.63 for the value of the labor, services, materials, equipment, and supplies furnished by it to the Project. Id. at ¶ 14. CARPI contends that despite it making a good faith request that WCA stay this action pending the resolution of the termination proposal with the Bureau, WCA refused to consent to a stay. Doc. 13 at 6. II. DISCUSSION a. Dismissal

Defendants argue that the Complaint fails to state a claim for which relief can be granted because “WCA’s claims are already pending before the Contracting Officer as part of the federal claims process.” Doc. 13 at 7.

2 Federal Acquisition Regulation 52.249–2, which was incorporated by reference into the Subcontract, provides for termination for convenience of the government. Under this regulation, the government “may terminate performance of work under this contract in whole or, from time to time, in part if the Contracting Officer determines that a termination is in the Government's interest.” 48 C.F.R. § 52.249–2(a).

3 When a contract is terminated for the convenience of the government, the contractor may submit a termination settlement proposal. FAR § 52.249–2(e), 48 C.F.R. § 52.249–2(e). A settlement proposal is “a proposal for effecting settlement of a contract terminated in whole or in part, submitted by a contractor or subcontractor in the form, and supported by the data, required by this part.” FAR § 49.001, 48 C.F.R. § 49.001. Rule 12(b)(6) authorizes a court to dismiss a complaint for “failure to state a claim upon which relief can be granted.” Fed. R. Civ. P. 12(b)(6). “The nature of a Rule 12(b)(6) motion tests the sufficiency of the allegations within the four corners of the complaint after taking those allegations as true.” Mobley v. McCormick, 40 F.3d 337, 340 (10th Cir. 1994). The complaint's sufficiency is a question of law, and, when considering a Rule 12(b)(6) motion, a court must accept

as true all of the complaint's well-pled factual allegations, view those allegations in the light most favorable to the non-moving party, and draw all reasonable inferences in the plaintiff's favor. See Tellabs, Inc. v. Makor Issues & Rights, Ltd., 551 U.S. 308, 322 (2007); Smith v. United States, 561 F.3d 1090, 1098 (10th Cir. 2009). At this early stage of litigation, the Court cannot definitively say that WCA has failed to state a claim that is plausible on its face. Defendant’s argument for dismissal relies on matters outside the pleadings, namely the ongoing settlement negotiations with the Government. The outcome of these negotiations will potentially precipitate further legal and factual development. See Naranjo v. Victor, 625 F. Supp. 3d 1140, 1147 (D. Colo. 2022) (“[T]he Court finds that such

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United States of America, for the use of WCA Construction, LLC v. C.A.R.P.I., USA, INC. and Federal Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-of-america-for-the-use-of-wca-construction-llc-v-nmd-2026.