Reservation Ranch v. United States
United States Court of Federal Claims
39 Fed. Cl. 696 (1997)
- Written by Colette Routel, JD
Facts
In 1990, the United States Forest Service (Forest Service) (defendant) executed a contract with Reservation Ranch (the ranch) (plaintiff), authorizing the ranch to harvest a large amount of timber from Six Rivers National Forest in California. The contract provided that the Forest Service could cancel the contract at any time if it determined that logging would threaten the continued existence of the spotted owl, a species protected under the Endangered Species Act of 1973. If the Forest Service canceled the contract for this reason, the contract also indicated that the ranch would not be entitled to normal compensatory damages (e.g., lost profits). In 1992, the Forest Service used this provision to cancel the contract, and the ranch sued seeking $5.5 million in damages. The ranch argued that the contract provisions limiting the ranch’s damages were not authorized by law because NFMA itself did not limit damage awards for breach of contract, while the Forest Service contended that NFMA did not prevent the agency from limiting its liability for damages through explicit contract provisions.
Rule of Law
Issue
Holding and Reasoning (Merow, J.)
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