Sikorsky Aircraft Corp. v. United States
105 Fed. Cl. 657
| Fed. Cl. | 2012Background
- Government seeks ~$80 million for Sikorsky CAS 418 noncompliance from 1999–2005; two affirmative defenses raised: statute of limitations and accord and satisfaction.
- CDA provides two limitations: six-year accrual and post-claim 90-day/one-year window for appeals/suit.
- Dispute centers on accrual timing: whether government knew or should have known of potential noncompliance by 2002.
- Key events: 1999 accounting change, 1999 audit found no material 1999 impact, 2004 audit found potential noncompliance, 2008 final decision demanded payment.
- Parties dispute whether 2005 agreement (accord and satisfaction) resolved past damages; if so, timing of claim could be tainted.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| When did the government’s CAS claim accrue? | Sikorsky | Government | Dispute; accrual hinges on notice and regulatory framework, not simply administrative steps. |
| Did Crown Coat controls govern accrual here? | Sikorsky | Government | Crown Coat does not govern CDA accrual; two CDA accrual rules control. |
| Did an accord and satisfaction exist to bar the claim? | Sikorsky | Government | Existence of meeting of the minds fact-bound; summary judgment denied. |
Key Cases Cited
- Crown Coat Front Co. v. United States, 386 U.S. 503 (1967) (accrual awaiting completion of mandatory admin. proceedings under the contract disputes framework)
- Raytheon Co. v. United States, 104 Fed.Cl. 327 (2012) (discusses accrual under FAR 33.201 and CDA timing)
- United States v. Commodities Export Co., 972 F.2d 1266 (1992) (agency accrual timing; cannot delay accrual via internal procedures)