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.”
Insights
Client Alert | 2 min read | 07.01.25
DoD Establishes New DOGE Approval Process for ITC&MS and A&AS Contracts
On June 23, 2025, the DoD issued a memorandum, “Implementation of Department of Government Efficiency Cost Efficiency Initiative,” to establish a new DOGE approval process for unclassified IT consulting and management services (ITC&MS) contracts or task orders (TOs), and advisory and assistance services (A&AS) contracts or TOs. The memorandum establishes a formal approval process, which directs DOGE to review and provide input for certain contract requirement packages included in Defense Secretary Pete Hegseth’s May 27, 2025 directive, “Implementation of Executive Order 14222 – Department of Government Efficiency Cost Efficiency Initiative” (“Contract Guidance”).
Client Alert | 10 min read | 07.01.25
Ninth Circuit Decision Underscores Increasing False Claims Act Risks to U.S. Importers
Client Alert | 8 min read | 06.30.25
Client Alert | 3 min read | 06.30.25