Sunday, October 8, 2023

SMART USE OF OUR SERVICES

Our good friend suggests prospective and existing clients would benefit from our 50 years of experience in federal government contracts. 

Yes. A phone call or Zoom meeting could result in avoiding a problem or enhancing profitability. 

One example is protesting a contract award. You need an independent view based on maximum experience. It may not be wise to protest.

You think you have a claim, but what will the government argue in response. 

You have written a claim but need an independent review of its chances of success.

What is the best precedent to cite in support of your constructive change?

Is ADR a good idea, and if so, when?

We will keep adding to this list as we go. The point is we always are value-added. You and your team are intelligent but may need to catch up on something important. Experience is the best teacher; we have been in your situation before.

bill@spriggslawgroup.com


 

Saturday, October 7, 2023

THE AMERICAN CRISIS AND WHAT TO DO ABOUT IT REDUX

The situation is critical. We need the strength of the most effective bully pulpit. We need to take truth to power and superior power to weaker power. What is the world's most powerful coalition? The U.S. military-industrial complex. We need the leaders of the military group to step up to the challenge of their oath and speak out.

We propose that military and industry leaders meet and agree democracy is the path to follow. They should then sign a declaration of support for constitutional democracy and strong opposition to any form of minority or autocratic rule. All media should publish this "open letter" to all Americans. The letter should oppose specifically the election of any "would-be dictator." To the extent the military/industry leaders deem it appropriate, they should propose additional actions to publicize the letter.

We need to brainstorm precisely what substance goes into the letter, who should sign it, and what is done with it. The purpose is to reaffirm democracy and to marginalize those who would usher in autocracy,

For those of you who may not know, military officers take the following oath:

"I, William J. Spriggs, having been appointed an officer in the Marine Corps of the United States, do solemnly swear (or affirm) that I will support and defend the Constitution of the United States against all enemies, foreign or domestic, that I will bear true faith and allegiance to the same; that I take this obligation freely, without any mental reservation or purpose of evasion; and that I will well and faithfully discharge the duties of the office upon which I am about to enter; So help me God."


LYING IS WRONG

At least half of us think lying is okay or good if it at least serves our agenda. Beliefs trump facts if the beliefs are strong. Opinions are valid if the opinionators are in the right camp.  In any event, beliefs are more reliable than facts. All facts cannot be trusted to be true. Beliefs are the new truth. The Bible is accurate, and all accounts of history since 200 A.D. are suspect. 

Science is just a bunch of theories. Man did not evolve from a monkey because no one has seen a monkey turn into a human being; the earth is flat. Mankind's moral code, prescribed in the Bible, must be followed, or one will go to Hell. The world is 6,000 years old. And Donald Trump is the only leader who knows and tells everyone the truth.

On and on. And each lie is verified by faith, belief, and Mr. Trump.

Many of us spend our lives seeking the truth. We want to know what is accurate, not imaginary. We follow science and its method of seeking evidence to discover the truth. On the other hand, half of us do not question or engage in critical thinking but instead wait to be told the truth.

What happened to lying is wrong? Wasn't that the first thing we learned? Truth matters. Reality matters. We will not survive as a species if we don't reverse this trend. 

                  

MY OATH

 Once a Marine, always a Marine. The oath below, made in May of 1961, is for always.

"I, William J. Spriggs, having been appointed an officer in the Marine Corps of the United States, do solemnly swear (or affirm) that I will support and defend the Constitution of the United States against all enemies, foreign or domestic, that I will bear true faith and allegiance to the same; that I take this obligation freely, without any mental reservation or purpose of evasion; and that I will well and faithfully discharge the duties of the office upon which I am about to enter; So help me God."

THE AMERICAN CRISIS AND WHAT TO DO ABOUT IT

We can all agree the American body politic is in crisis. So much so that polarization has led to paralysis. We need to debate the essence of the problem. We propose the question is whether we want to continue as a democracy or as an autocracy.

We submit the crisis is that we are shedding the original constitutional democracy in favor of autocracy, perhaps even theocracy. The evidence in support of this view is the minority control of the cult leader and would be autocrat Donald Trump and his followers.

The elected politicians have demonstrated they cannot agree on the following course. Assuming the people wish to govern themselves in a democracy, we propose a course of action to right the ship before it sinks.

We need a national referendum on whether to proceed as a democracy. That takes too long and is a daunting task. A vital election looms around the corner. Action must be taken now.

We propose that military and industry leaders meet and agree democracy is the path to follow. They should then sign a declaration of support for constitutional democracy and strong opposition to any form of minority or autocratic rule. All media should publish this "open letter" to all Americans. The letter should oppose specifically the election of any "would-be dictator." To the extent the military/industry leaders deem it appropriate, they should propose additional actions to publicize the letter.  
bill@spriggslawgroup.com

Wednesday, October 4, 2023

SHUTDOWN TEMPORARILY AVERTED

SHUTDOWN AVERTED? WHAT HAS CHANGED?

Nothing. Only the delay in the event has changed. Everything we have said still applies. A shutdown is a constructive suspension redressable under the Changes clause (because of how the Suspension clause is worded). That means if a contractor keeps good records of the immediate impact and the impact on the unchanged or original work, the contractor should be able to recover on its claim notwithstanding the government's sovereign act defense.

Why is the shutdown a constructive suspension? Read the first sentence of the clause. It provides "suspend, delay or interrupt all or any part of the work." The only question is if and how that impacts the contractor. Constructive, like any other government act or omission, can be a constructive change.

Yes, try to get direction from your contracting officer. If the past is prologue, he will not respond. You are on your own. Seek expert advice, but above all, use your sound business judgment. Weigh the risks. If the government is foolhardy enough to terminate for default, the suspension as a sovereign act is an absolute defense to the termination.


Saturday, September 30, 2023

GOVERNMENT SHUTDOWN CLAIMS

Here we go again. Use the word search feature in the upper left-hand corner to find what we have written about government shutdowns. Be sure to add the government's sovereign act defense. In summary, the shutdown is a constructive suspension that is redressable under the Changes clause; declaratory relief is also available, and the government contract defense should not absolve the government of responsibility.

Why is the shutdown a constructive suspension? The first sentence of the Suspension clause provides: "suspend, delay. or interrupt all or any part of the work." The clause also provides that the remedy is under any equitable adjustment clause.

Yes, try to get direction from your contracting officer. If the past is prologue, he or she will not respond. You are on your own. Seek expert advice, but above all, use your sound business judgment. Weigh the risks. If the government is foolhardy enough to terminate for default, the suspension as sovereign act is an absolute defense to the termination.

Read what I have written about REAs and claims. The quickest way to ADR, appeal, and judicial resolution of the damage caused by the shutdown is to file a claim and skip the REA. Your contracting officer will likely not feel responsible and will not issue a final decision, leaving you to file an appeal based on deemed denial.

In fact, start with a nonmonetary claim to avoid the 60-day wait for the contracting officer's decision. You can add the monetary claim later. In both cases, you need to ask for the conclusion and open with an attempt to go ADR from the start.

HOW TO WRITE A CLAIM

1.    Send a letter in simple, concise terms to the contracting officer who claims relief.

2.      The letter says it is a claim under the Contract Disputes Act of 1978 and FAR Parts 2.101 and 33.201 through 214.

3.      In the letter, state that you request a final decision of the contracting officer as required by the Contract Disputes Act of 1978 and FAR 33.211.

4.      Certify the claim (if it exceeds $100,000.00) as follows:  I certify that the claim is made in good faith, that the supporting data are accurate and complete to the best of my knowledge and belief, that the amount requested accurately reflects the contract adjustment for which the contractor believes the government is liable; and that I am duly authorized to certify the claim on behalf of the contractor.  Do not deviate from this language found in FAR 33.207(c).

5.      Be sure to state a sum certain as the claim amount.

6.      Point out that interest runs on the claim from the time of its receipt.  FAR 33.208.

7.      Be sure to request a final decision as required by FAR 33.211.

8.      Appeal the decision (or the failure to render one) to the appropriate Board.

bill@spriggslawgroup.com

Tuesday, September 26, 2023

FREE GOVERNMENT CONTRACTS WEBINAR

Announcing a Free Webinar for All Levels of Experience 

Spriggs Law Group, with over 50 years of experience, invites your organization to reserve up to six people to attend a 60-minute Zoom webinar during which Mr. Spriggs will discuss the topics listed below, and he will answer questions. You and they will receive a copy of the 28-page slide PowerPoint written presentation and a copy of the meeting recording.

• How to excel at contract management.

• Identifying the contract performability risks and language conflicts.

• Monitoring contract performance to spot changes and compensable delays.

• Identifying constructive changes and engagement with the warranted contracting officer.

• Implied by law government obligations.

• Timing and staffing of dispute resolution, including negotiation and ADR.

• REAs, claims, calculating damages, transparency, appeals, and declaratory judgments.

• Terminations and subcontracts considerations. 

Email me with at least two suggested dates and times. I also will need the participants' email addresses so I can send them the Zoom invitation. bill@spriggslawgroup.com

Sunday, September 24, 2023

EXTENDING EQUITY IN GOVERNMENT CONTRACTING

 

Just how far should the concept of equity extend in government contracting? The regulation dealing with terminations for convenience makes it clear that when the government enters the marketplace and contracts with a private party it must exercise equity when it decides to terminate the contract for its own convenience. Read FAR 49.201. The concept of equity is discussed in practical terms. From that regulation is quite clear the government owes a special duty to a contractor when the government exercises the unique to its system unilateral termination of an existing contract.

The concept of equity expressed in the termination for convenience regulation should be extended to other aspects of government procurement. It makes sense that the rules be relaxed for convenience terminations. However, when it comes to the allocation of risk relating to changes and disputes, equity should be extended to permit avoidance by standards familiar in the private commercial world. The government should extend the same consideration to its contractors as in the private contracting sector when it shuts down and refuses to pay its bills. Public contracting should allocate risk to the government in any situation where to act otherwise would unduly punish the contractor or unjustly enrich the government.

bill@spriggslawgroup.com

Sunday, September 3, 2023

THE CONTRACTOR'S RIGHT TO STOP WORK

When does the contractor have the right to stop work?

The Court of Appeals for the Federal Circuit has held that “[u]pon material breach of

a contract, the non-breaching party has the right to discontinue the performance of the contract

Stone Forest, 973 F.2d at 1550; Malone v. United States, 849 F.2d 1441, 1446 (Fed.

Cir. 1988) (holding that material breach by the Government “provides Malone with a legal right

to avoid the contract [and] discharges Malone’s duty to perform”); Kap-Sum Properties, 13

BCA at 173,833 (citing Malone). The Court further explained, “The choice of remedy

is generally with the non-breaching party, and only in exceptional circumstances will equity

require the non-breaching party to continue to perform the remainder of the contract.” Stone

Forest, 973 F.2d at 1552. “[I]f a contract is not clearly divisible, by the

intention of the parties, the breaching party can not require the non-breaching party to

continue to perform what is left of the contract.” Id.

What is a material breach by the government?

In determining whether a failure to render or to offer performance is material,

the following circumstances are significant:

(a) the extent to which the injured party will be deprived of the benefit

which he reasonably expected;

(b) the time to which the injured party can be adequately compensated for

the part of that benefit of which he will be deprived;

(c) the time to which the party fails to perform or to offer to perform

will suffer forfeiture;

(d) the likelihood that the party failing to perform or to contribute to perform

will cure his failure, taking account of all the circumstances, including any

reasonable assurances;

(e) the extent to which the behavior of the party failing to perform or to

offer to perform comports with standards of good faith and fair dealing.

Practical solution

If the breach goes to the essence of the contractor's expectation, the breach most likely will be determined to be material. At that point, the contractor is well advised to seek declaratory relief from the board or court.

Failure to do so could be a waiver of the breach. Stopping work without judicial relief could result in termination for default. The pendency of litigation is not a legal defense to a T for D.

Many factors contribute to the decision to stop work before the judicial determination of declaratory relief. Most are not strictly related to the merits of the legal arguments.

bill@spriggslawgroup.com