Sparton DeLeon Springs, LLC, ASBCA No. 60416

Appellant Sparton DeLeon Springs, LLC appealed the government's overpayment claim under two defense contracts to the ASBCA (ASBCA No. 60416).
On 28 December 2016 the Board granted summary judgment to Sparton, concluding the government’s claim was time-barred by the six-year statute of limitations in the Contract Disputes Act (41 U.S.C. § 7103).
The government moved for reconsideration, arguing (1) the Board applied the wrong accrual standard for when a claim accrues and (2) attaching a January 2007 DCAA Contract Audit Manual excerpt as evidence.
The Board treated the DCAA manual excerpt as not newly discovered and therefore not a basis for reconsideration.
The Board found no meaningful difference between the government’s phrasing (“reasonably should have known”) and the FAR accrual standard (“should have been known”) and declined to reopen the legal question.
The Chairman denied the government’s request to refer reconsideration to the Board’s Senior Deciding Group; the Board denied the motion for reconsideration on 18 May 2017.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the government’s motion for reconsideration should be granted	Reconsideration improper; prior decision stands	Motion seeks to re-litigate issues and introduce evidence not newly discovered	Denied — motion re-argues decided issues and cites non-new evidence
Proper accrual standard for statute-of-limitations defense (when government’s claim accrues)	The Board applied FAR accrual language: claim accrues when it "should have been known"	Government contends the correct standard is "reasonably should have known," implying a different accrual point	Denied — Board found no conceptual difference between the two phrasings and that accrual was correctly determined

( No listed authorities with official reporter citations in the opinion met the requirement for inclusion )