Reflectone, Inc. v. Dalton

60 F.3d 1572 (1995)

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Reflectone, Inc. v. Dalton

United States Court of Appeals for the Federal Circuit
60 F.3d 1572 (1995)

  • Written by Liz Nakamura, JD

Facts

Reflectone, Inc. (plaintiff) entered into a fixed-price contract with the United States Navy to update helicopter weapons system trainers. During Reflectone’s performance, there were several rounds of delays. Reflectone submitted a certified request for equitable adjustment (REA) to the Navy seeking to recover approximately $267,000 in costs related to the delays and claiming that the Navy’s failure to timely provide the required government-furnished property caused the delays. The Navy’s contracting officer issued a final decision denying Reflectone’s REA. Reflectone appealed the denial to the Armed Services Board of Contract Appeals (Board). The Board dismissed Reflectone’s appeal, holding that it did not have subject-matter jurisdiction because Reflectone’s REA was not a valid Contract Disputes Act (CDA) claim. Specifically, the Board held that Reflectone’s REA was not a valid CDA claim because the $267,000 Reflectone demanded in the REA had not been in dispute prior to Reflectone submitting its REA. Reflectone appealed.

Rule of Law

Issue

Holding and Reasoning (Michel, J.)

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