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Claim Accrual and the Continuing Claims Doctrine: Board Has Jurisdiction Over Claim Comprised of Separate and Distinct Events that Fell within the CDA’s Six-Year Statute of Limitations Period

Client Alert | 1 min read | 05.03.22

In Lockheed Martin Aeronautics Company, ASBCA No. 62209 (a C&M case), the Armed Services Board of Contract Appeals (Board) held that the contractor’s claim, seeking recovery for impacts of over-and-above repair work during contract performance, was timely filed under the Contract Disputes Act’s six-year statute of limitations—rejecting an Air Force Motion for Summary Judgment and granting cross-motions filed on behalf of Lockheed Martin.  Recognizing that a contractor’s claim cannot accrue before the events that fix the liability of the government, the Board held Lockheed Martin’s claim did not have a single accrual date but, rather, multiple accrual dates based upon when the government approved each repair.  The Board separately held that those government approvals represented “the type of single-topic . . . yet repeated and distinct events” making Lockheed Martin’s claims timely under the well-recognized “continuing claim doctrine.”

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Client Alert | 2 min read | 12.19.25

GAO Cautions Agencies—Over-Redact at Your Own Peril

Bid protest practitioners in recent years have witnessed agencies’ increasing efforts to limit the production of documents and information in response to Government Accountability Office (GAO) bid protests—often will little pushback from GAO. This practice has underscored the notable difference in the scope of bid protest records before GAO versus the Court of Federal Claims. However, in Tiger Natural Gas, Inc., B-423744, Dec. 10, 2025, 2025 CPD ¶ __, GAO made clear that there are limits to the scope of redactions, and GAO will sustain a protest where there is insufficient evidence that the agency’s actions were reasonable....