Robinson v. United States
Headline: Court upholds liquidated delay penalties and repair cost deductions, ruling a construction contractor must pay agreed delay fines and reimburse the Government for warped window repairs despite some Government-caused delays.
Holding: In a construction contract dispute, the Court affirmed that agreed liquidated damages apply to days the contractor caused delay and upheld Government deductions for repair costs under the contract’s one-year guarantee.
- Requires contractors to pay agreed daily delay penalties for days they are found at fault.
- Allows the Government to deduct repair costs when contractors refuse to fix defective work.
- Confirms court findings allocating delay days determine who owes liquidated damages.
Summary
Background
A private contractor agreed to finish the interior of the new custom house in New York City for the United States. The original contract set a completion date of October 15, 1906 and a price of $1,037,281.69. A supplemental agreement added work, raised the price by $200,041.01, and extended completion to June 1, 1907. The work finished 121 days after that date. The Government deducted $45,780 as liquidated damages at $420 per day for delay; the contractor sued. The Court of Claims found 61 days chargeable to the contractor and awarded $20,160 of the withheld sum to the contractor.
Reasoning
The Court examined whether the contract’s liquidated-damage clause still applied when the Government had caused some delay. The contract expressly allowed extra days for government-caused delay and required a fixed daily penalty for days not caused by the Government. The Court said the clause was valid, not against public policy, and that the Court of Claims’ specific factual allocation of delay days controlled. The Court also addressed a one-year guarantee for window sashes. The contractor had suggested changing from solid oak, the Government declined, warping occurred within a year, and the contractor refused to make repairs. The Court found warping due partly to unsuitable oak and poorer materials or workmanship and upheld the Government’s deduction for repair costs.
Real world impact
The decision enforces clear contract terms: contractors must pay agreed daily penalties for days the record shows they caused delay, even if the Government caused other delays. Contractors also remain responsible under express repair guarantees and cannot avoid deductions when they refuse remedial work.
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