Young Associates, Inc. v. United States

471 F.2d 618, 200 Ct. Cl. 438, 1973 U.S. Ct. Cl. LEXIS 7
CourtUnited States Court of Claims
DecidedJanuary 18, 1973
DocketNo. 787-71
StatusPublished
Cited by17 cases

This text of 471 F.2d 618 (Young Associates, Inc. v. United States) is published on Counsel Stack Legal Research, covering United States Court of Claims primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Young Associates, Inc. v. United States, 471 F.2d 618, 200 Ct. Cl. 438, 1973 U.S. Ct. Cl. LEXIS 7 (cc 1973).

Opinions

Davis, Judge,

delivered the opinion of the court:

Plaintiff Young Associates, Inc. contracted in June 1964 with the National Park Service of ¡the Department of the Interior to do some construction work, including lighting and [440]*440tile-lining, in a new road tunnel built in Rook Creek Park in Washington, near the National Zoological Park. The work was accepted as completed in November 198b, but the Government thereaf ter assessed liquidated damages at $100 per day for 144 days of unexcusable delay in completion, a total of $14,400. This sum was deducted from the amount due the contractor.

Young Associates appealed the imposition of liquidated damages to the Department of the Interior Board of Contract Appeals, which affirmed the contracting officer’s determination. I'BCA No. 557-4-66,67-2 BOA ¶ >6676; 69-1 BCA f 7419 (Dec. 1968). This action to review the administrative holding raises purely legal issues; the facts are not now disputed 1 and both sides have moved for summary judgment.

Plaintiff’s major challenge is that the board erred in ruling that the contract should be construed as containing a liquidated-damages provision (under which the contracting officer thought he was acting). It is agreed that liquidated damages could not be imposed unless authorized by the contract, and it is also common ground that a liquidated-damage provision was not mandatory for this type of contract but was optional at the election of the contracting officer. The basic question is whether such a requirement became part of this undertaking.

The default-termination clause of the contract (article 5 of the 1961 edition of Standard Form 2S-A) provides that the Government can terminate the contractor’s right to proceed if he delays in performance, and also that “[w]hether or not the Contractor’s right to proceed with the work is terminated, he and his sureties shall be liable for any damages to the Government resulting from his refusal or failure to complete the work within the specified time.” This standard-form article then goes on to say:

(b) If fixed and agreed liquidated damages are provided in the contract and if the Government so terminates the Contractor’s right to proceed, the resulting damage will consist of such liquidated damages until such reasonable time as may be required for final com[441]*441pletion of the work, together with any increased costs occasioned the Government in completing the work.
(c) If fixed and agreed liquidated damages are provided in the contract and if the Government does not so terminate the Contractor’s right to proceed, the resulting damage will consist of such liquidated damages untü the work is completed or accepted.

Invoking subparagraph (c), defendant points to section 8.8 of Standard Specification FP-612 (FP-61 was expressly incorporated as a whole and without limitation into the contract) :

FAILURE TO COMPLETE WORK WITHIN CONTRACT TIME. Pursuant to the general provisions of the contract providing for liquidated damages for each calendar day of delay until the work is completed, the total amount of liquidated damages shall be as calculated from the daily charge given in table 8-1.

In turn, table 8-1 sets forth a graduated scale of “daily charge [s] for liquidated damages for each calendar day of delay”, rising from $30 to $300, depending on the original contract amount. For an agreement of the initial size of plaintiff’s ($312,712.40), the charge was $100 a day. This, says defendant, squarely authorizes the assessment made here.

Plaintiff’s point is that this ehain-of-contract-authority which the Government threads from article 5 (c) to section 8.8 to table 8-1 falls apart when examined closely. Article 5 (c), it is argued, does not itself authorize liquidated damages but is phrased hypothetically — “[¿]/ fixed and agreed liquidated damages are provided in the contract” (emphasis added). The next step in the challenge is that section 8.8 of FP-61 cannot be the contract provision providing for liquidated damages to which article 5(c) refers because, when 8.8 says “pursuant to the general provisions of the contract providing for liquidated damages”, it must be referring to some other part of the agreement, not to itself— and there is no other such provision. The last link in the contractor’s reasoning is that table 8.1 is merely a bare schedule, [442]*442not at all a provision itself imposing damages or authorizing them to be assessed. The conclusion, according to plaintiff, must be that this contract, as written and signed, did not contemplate or authorize any award of liquidated damages to the Government.

This is far from a frivolous argument. In tying the standard construction form with FP-61, the contracting officer failed to bind up the loose ends of language. On one reading, article 6 (c) seems to refer to something in FP-61, and then FP-61 appears to hark back to the standard form — in a sort of contractual renvoi. It would have been much better practice to insert a clause affirmatively and unequivocally declaring that liquidated damages would be imposed for unexcused delay.3

Nonetheless we are not persuaded to accept the contractor’s argument. Though they are not as clear as they should have been, the terms of this contract can be reasonably understood as granting authority for the assessment of liquidated damages. As the board observed, article 5(c) does not say, “If a clause directing that liquidated damages shall be imposed is provided in the contract”, but merely, “If fixed and agreed liquidated damages are provided in the contract.” Literally, section 8.8 and table 8-1 of FP-61 do in fact “provide” such “fixed and agreed liquidated damages”, and accordingly the single stated condition to the operability of article 5(c) is precisely fulfilled. The latter provision being thus triggered, under its terms “the resulting damage [from the contractor’s delay] will consist of such liquidated damages until the work is completed or .accepted.” This reading is certainly rational, fitting as it does with the literal language of article '5 (c) and the presence in the contract of both section 8.8 and table 8-1.

'If the contractor had shown that from the 'beginning it understood the agreement otherwise — not to provide at all for liquidated damages — we might well have upheld its position on the ground that such a reading, opposite to the [443]*443Government’s, would likewise be reasonable, and that the risk of the ambiguity should lie with the drafter. But the record is quite to the contrary. During performance and before this controversy arose, plaintiff clearly and affirmatively indicated that it considered the contract to authorize the imposition of liquidated damages.

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Bluebook (online)
471 F.2d 618, 200 Ct. Cl. 438, 1973 U.S. Ct. Cl. LEXIS 7, Counsel Stack Legal Research, https://law.counselstack.com/opinion/young-associates-inc-v-united-states-cc-1973.