Overview
Case summary
This case concerns a claim against the District of Columbia for the difference between contract rates and 'board rates' for public works performed in the 1870s. Following the passage of the Act of February 13, 1895, which allowed for new trials for claimants who had not received board rates, the claimant sought a retrial. The Court of Claims held that the 1895 Act was intended to provide an equitable remedy to place claimants on equal footing with those who had received board rates, but it did not authorize a full retrial of all issues. Furthermore, the court determined that judgments under the 1895 Act should follow the same form as those under the 1880 Act, including the allowance of interest from the time the claim was due and payable.
Abstract
The case involves a claim against a government entity for the difference between contract rates and board rates on public works performed decades earlier. Following special legislation allowing new trials for claimants who had not received board rates, the court ruled that the act provided an equitable remedy to equalize treatment but did not permit a full retrial of all issues, and judgments must follow the form of prior acts including interest from when the claim was due. Judgment was awarded to the claimant for the specified amount plus interest from the due date.
Procedural posture
Legal categories
Case record
Issues & holdings
De novo interpretation of the Act of 1895.
The court held that the jurisdiction is limited to the application of board rates to items already established, not a full reinvestigation of the case.
De novo interpretation of the Act of 1895 in conjunction with the Act of 1880.
The court held that the 1895 Act is amendatory to the 1880 Act and carries forward the same interest provisions.
Holdings of the court
Timeline
No timeline recorded.
Facts & evidence
Incident
Key facts
4 facts- Claimant performed work under contract No. 320 involving macadam.
- Claimant was originally paid at contract rates rather than the higher 'board rates' established by the Board of Public Works.
- The Act of February 13, 1895, allowed for a new trial to recover the difference between contract rates and board rates.
- The court calculated the balance due as $8,664.19 after deductions for stone costs.