5677956838

Office Automation & Training Consultants

January 19, 2011Judge Dickinson
DismissedContract InterpretationAccord & Satisfaction / Release / WaiverSmall BusinessCommercial Item

Office Automation & Training Consultants appealed for contract reformation due to an alleged unilateral mistake in its quote stemming from an incomplete solicitation. The Board granted the government's motion for summary judgment, denying the appeal.

Material Facts

  • The U.S. Army Corps of Engineers issued Solicitation No. W912P4-05-T-0001 to OATC under the SBA 8(a) set-aside program.
  • The solicitation requested quotes for various administrative and technical support services for two base years and three option years.
  • A hard copy of the Department of Labor (DoL) wage rates was not attached to the solicitation, but a link to the applicable wage determination was provided.
  • OATC submitted its quote on 1 December 2004, which included base and overtime hourly unit prices.
  • The Contracting Officer expressed concerns about OATC's quoted overtime prices being unreasonably high compared to government estimates.
  • The government awarded Contract No. W912P4-05-P-0019 to OATC on 14 January 2005.
  • OATC did not request an increase in its unit prices after receiving updated wage determinations in 2006.
  • The contract ended by its own terms on 31 December 2006.
  • OATC submitted a request for equitable adjustment on 14 January 2008, claiming a unilateral mistake in its bid.
  • The contracting officer denied the REA and a subsequent certified claim, leading to the appeals.

Parties

Appellant
Office Automation & Training Consultants
Respondent Agency
U.S. Army Engineer District, Buffalo
Contract Number
Contract No. W912P4-05-P-0019
Open Official Decision PDF (asbca.mil)AI-analyzed, grounded in the decision text. Verify against the official PDF before relying on it.

Full Legal Analysis

Create a free account to read the complete grounded legal brief for this decision, including the holding, every issue the Board decided, quantum, verified citations, and the case's citation graph.

Holding & Legal Reasoning

The Board's holding, background, and procedural posture for this decision.

Issues Presented

Every issue the Board decided, with its determination, reasoning, and supporting authority.

Quantum & Recovery

The claimed, awarded, and net dollar amounts at issue, itemized where the record supports it.

Verified Authorities & Citations

Every cited FAR, DFARS, CAS, and case-law authority, cross-checked against the source text.

Practitioner Takeaways

Practical guidance for contractors and counsel, distilled from the Board's ruling.

Similar Cases

Related decisions surfaced by semantic search across the full analyzed corpus.

Citation Graph

An interactive graph of this case's cited authorities, judge, agency, and related decisions.

Related Decisions

Same Judge

Same Year

Same Issue

Newsletter

New decisions every Monday

GovConDash Weekly lists the decisions GAO, the boards, the courts and SBA OHA released that week, alongside the FAR Overhaul deviations and proposed rules that reach every contractor. Free.

Free, weekly, and one click to unsubscribe. We send a confirmation email first. See our Privacy Policy.