Perkins—campbell Co. v. United States
Headline: A wartime manufacturer’s attempt to reform and reopen a government award is blocked; Court affirms denial, leaving the company without extra payment after it accepted the Government’s settlement.
Holding: The Court affirmed the lower court and held that the company cannot reform or recover extra payment because it accepted the award as full payment and failed to show a shared mistake, fraud, or an authorized government promise.
- Makes it difficult for contractors to reopen accepted government awards.
- Requires clear, authorized government agreement to reserve unpaid claims.
- Prevents extra payment without proof of shared mistake or fraud.
Summary
Background
A manufacturing company contracted with the War Department in 1917 to make 35,000 sets of ambulance harness and delivered some sets. The parties later negotiated a cut to 20,000 sets and an offer to substitute 10,000 cart harness at a higher price. The War Department cancelled 15,000 ambulance sets and approved an award for 10,000 cart harness, but the new contract was not executed before the Armistice. The company paused production, incurred more than $70,000 in expenses preparing to switch, then filed two wartime claims under a statute allowing payment for agreements not executed as prescribed by law. The Claims Board awarded sums for both contracts, the company accepted and was paid, and later administrative boards denied further reimbursement for the 15,000 cancelled ambulance sets.
Reasoning
The key question was whether the company could reform the Claims Board award and get extra money for the 15,000 sets. The Court said no. It found the company accepted the award “in full discharge” of the original contract and the petition did not allege facts showing a shared mistake, fraud, duress, or that the officers who allegedly made contrary promises had authority to bind the Government. The Court treated the award as an adjudication on the claims and concluded the petition failed to show the special circumstances required to change that final settlement.
Real world impact
The decision leaves the company without the extra $21,868.89 it sought and affirms that awards accepted as full payment are hard to reopen. Contractors who accept government settlements should secure clear, written reservations or authorized agreements if they want to preserve unpaid claims.
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