[Claim for Payment Due to Navy Contract Termination]

B-215792: Jan 8, 1985

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An individual claimed amounts allegedly due her under a Navy contract that she argued was improperly terminated. Specifically, the claimant sought payment for the period she was unemployed as a result of the termination of an instructional course, plus reimbursement for expenses incurred in anticipation of continuing the course for a full year. The claimant argued that she had received oral assurances that the contract for the course would last for a full year. The Navy terminated the contract after what it believed to be the anticipated length of the course, which was less than a full year. GAO held that, although the informal discussions caused the claimant to believe that the contract period was for a full year, the discussions were not legally binding on an agency. Although GAO has allowed payment for services on a quantum meruit basis if the government has received a benefit, the claimant's unemployment for the remainder of the year provided no such benefit. Reimbursement was also denied for expenses incurred in anticipation of a year-long course, since the Navy only benefited to the extent that instruction was provided. Accordingly, the claim was denied.