Overview
Case summary
The claimants sought payment for work performed under contracts with the District of Columbia. A referee initially found for the claimants but also allowed a counterclaim for the District based on overpayments. Following the passage of the Act of February 13, 1895, which mandated the use of board rates for all such claims, the claimants excepted to the referee's report. The Court of Claims held that the Act of 1895 required the court to set aside the counterclaim and that, because the principal of the counterclaim was extinguished by the statute, the associated interest was also extinguished.
Abstract
Claimants sought payment for work under government contracts, where a referee initially awarded their claim but allowed a counterclaim for overpayments. After a statute mandated use of board rates for such claims, the court set aside the counterclaim, extinguishing both principal and interest. Judgment was entered for claimants for the full amounts due under the statute.
Procedural posture
- Claimants' exception to the referee's finding of a counterclaim for overpayment at board rates.
- Claimants' exception to the assessment of interest on the counterclaim.
Legal categories
Case record
Issues & holdings
de novo
The Act of February 13, 1895, explicitly mandates the allowance of board rates, thereby nullifying the counterclaim.
Issue preserved for review
de novo
When the principal of a debt is extinguished by statute, the interest is also extinguished.
Issue preserved for review
Holdings of the court
Timeline
No timeline recorded.
Facts & evidence
Key facts
4 facts- Peter McNamara performed work for the District of Columbia under various contracts.
- A referee found amounts due to McNamara but also found a counterclaim for the District based on overpayments made at 'board rates' instead of 'contract rates'.
- Congress passed the Act of February 13, 1895, which mandated that the court allow rates established and paid by the Board of Public Works to all claimants.
- The Act of 1895 effectively nullified the basis for the District's counterclaim.