# Hartford Accident & Indemnity Co. v. District of Columbia

> District of Columbia Court of Appeals · February 2, 1982 · 441 A.2d 969

URL: https://www.frixlaw.com/law-library/cases/9645621

## Case

- **Full name:** HARTFORD ACCIDENT AND INDEMNITY COMPANY, Appellant, v. DISTRICT OF COLUMBIA, Et Al., Appellees; DISTRICT OF COLUMBIA, Et Al., Cross-Appellants, v. HARTFORD ACCIDENT AND INDEMNITY COMPANY, Cross-Appellee
- **Court:** District of Columbia Court of Appeals
- **Decided:** February 2, 1982
- **Citations:** 441 A.2d 969; 1982 D.C. App. LEXIS 279
- **Precedential status:** Published
- **Opinion:** Concurring in part by Ferren
- **Judges:** Newman, MacK, Ferren
- **Cited by:** 26 later opinions in the Frix Law Library

## Citator (automated)

- No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases.
- Full citator and citing cases: https://www.frixlaw.com/law-library/cases/9645621

## How later opinions describe it (automated extraction)

- rejecting a more limited application of the DCLMA and finding its provisions to extend to delay damages based on the guiding principle that the DCLMA’s payment bond “was designed to protect subcontractors supplying labor and materials to a government project”
- holding that an amended complaint for the balance due under a contract relates back to the original complaint for breach of that contract
- noting that, because amounts claimed for unpaid contract balance and for change order fluctuated throughout litigation, they were not liquidated

## Opinion text

FERREN, Associate Judge,
concurring in part and dissenting in part:
I generally concur in the opinion for the court but dissent in one respect. In United States f/u/b Mariana v. Piracci Construction Co., 405 F.Supp. 904 (D.D.C.1975), the court noted that claims for delay damages must be proved “with reasonable certainty and specificity.” Id. at 907 n.7. Given this test, I do not believe the trial court’s $8,502 award of delay damages to appellee is supportable on this record.

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/9645621. Public record. Not legal advice.