Baldi Bros, Inc. v. United States, 15-1300

Baldi Bros., Inc. sued the United States in the Court of Federal Claims under the Contract Disputes Act seeking $961,132.39 plus interest after a government contracting officer issued a final decision adverse to Baldi.
The dispute arose from a sealed-bid procurement and the government's invocation of FAR 14.407-4 (bid mistake rules) to deny relief to Baldi.
The contracting officer concluded Baldi’s bid did not qualify for correction/reformation/rescission because its corrected price would exceed the next lowest acceptable bid.
The parties agreed on the numeric bid figures; the dispute centered on application of FAR 14.407-4 and which price metric (total contract price or base item price) should be compared to the next lowest bid.
Government moved for (partial) summary judgment; the court treated it as a full summary judgment motion and addressed de novo the legal issues presented.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Jurisdiction: whether a final contracting officer decision exists	Baldi framed the case as an appeal under the CDA and relied on the COFD	Government maintained the CO issued a final decision and the court has CDA jurisdiction	Court had jurisdiction to review de novo after CO final decision and proceeded
Application of FAR 14.407-4(b)(2)(ii): which price metric controls	Baldi argued its bid could be corrected such that the corrected contract price would not exceed the next lowest acceptable bid	Government argued that, under either metric (total price or base item price) Baldi’s corrected price still exceeded the next lowest acceptable bid	Court held Baldi failed to show its corrected bid was less than the next lowest acceptable bid under either metric, so FAR relief was not warranted
Summary judgment: whether disputed facts precluded decision	Baldi implied factual disputes mattered to its claim	Government noted parties agreed on bid figures; legal application of those figures resolves the case	Court found no genuine material factual dispute; resolved the case as a matter of law for the government

M. Maropakis Carpentry, Inc. v. United States, 609 F.3d 1323 (Fed. Cir. 2010) (CDA requires a valid claim and a contracting officer’s final decision for jurisdiction)
Wilner v. United States, 24 F.3d 1397 (Fed. Cir. 1994) (court reviews contracting officer decisions de novo and gives no deference to findings of fact in CO decisions)
Celotex Corp. v. Catrett, 477 U.S. 317 (U.S. 1986) (summary judgment burden-shifting framework)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (U.S. 1986) (definition of materiality and genuineness for summary judgment)
Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (U.S. 1986) (viewing inferences in light most favorable to nonmoving party)
Mingus Constructors, Inc. v. United States, 812 F.2d 1387 (Fed. Cir. 1987) (standard for viewing evidence at summary judgment in government contract cases)
Ford Motor Co. v. United States, 157 F.3d 849 (Fed. Cir. 1998) (courts do not make factual findings on summary judgment)