The Federal Circuit recently clarified when a CDA claim for payment of money accrues for purposes of determining whether the CDA’s 6-year statute of limitations has run. In Kellogg Brown & Root Servs., Inc. v. Murphy, KBR filed the claim with the Army on May 2, 2012 for work done by its subcontractor in Iraq; thus, the critical date of accrual for limitations purposes was May 2, 2006. The ASBCA dismissed the claim, holding that the claim had accrued prior to May 2, 2006 and, thus, the limitations period had run prior to the filing of the claim. The Federal Circuit reversed and remanded for determination of the merits of the claim.
Continue Reading Recent Federal Circuit Decision Clarifies When a CDA Claim for Payment of Money Accrues