Calvin G. Wright Jack Critchfield Desert Forest Products, Inc., D/B/A Hutchinson, Carter Company v. U.S. Postal Service

Calvin Wright and other public-works subcontractors appeal the district court’s determination that the Contract Disputes Act, 41 U.S.C. §§ 601-613 , eliminated subject-matter jurisdiction over their actions to establish and foreclose equitable liens against the United States Postal Service. We reverse.

I.

In 1987, the United States Postal Service (“USPS”) hired RCR General Contractors, Inc. to construct a post office in Victorville, California. RCR, in turn, subcontracted with Calvin Wright, Jack Critchfield, and the Hutchinson, Carter Company (the “subcon tractors”) to perform various services for the project. RCR suffered financial difficulties, however, and was unable to pay the subcontractors as they fulfilled their contractual obligations. Ultimately, the USPS terminated RCR and completed the post office with another contractor.

RCR’s sureties subsequently refused to pay the subcontractors for their completed work. As a result, the subcontractors filed suit in district court against the USPS, seeking to establish and foreclose equitable liens for the value of their services. The district court dismissed the actions for lack of subject-matter jurisdiction, concluding that…