United States v. Spearin

Rule of Law:

When a party furnishes detailed plans and specifications for a contractor to follow, there is an implied warranty that those plans are adequate and suitable for the particular purpose. The contractor is not responsible for damages resulting from defects in the owner-provided specifications.

Facts:

• The United States Government contracted with Spearin to build a dry-dock at the Brooklyn Navy Yard according to plans and specifications prepared by the Government.
• The Government's plans required Spearin to relocate a 6-foot brick sewer that intersected the construction site, prescribing its specific dimensions, materials, and location.
• Spearin relocated the sewer in full compliance with the Government's specifications, and the Government accepted the completed section as satisfactory.
• Approximately one year later, heavy rain and a high tide caused the relocated 6-foot sewer to break from internal pressure, flooding the dry-dock excavation.
• An investigation revealed that the pressure was caused by an unknown dam within a connecting 7-foot sewer, which was not shown on the Government's plans or known to its officials.
• Although Government officials knew the area had a history of sewer overflows, this information was not communicated to Spearin.
• Spearin notified the Government that he would not resume work unless the Government assumed responsibility for the damage and remedied the unsafe sewer conditions.
• The Government insisted that Spearin was responsible for the repairs and, after a fifteen-month dispute, annulled the contract.

Procedural Posture:

• Spearin sued the United States in the Court of Claims, seeking damages for breach of contract.
• The Court of Claims (the court of first instance) entered a judgment in favor of Spearin for $141,180.86.
• Both the United States Government (as appellant) and Spearin (as cross-appellant) appealed the judgment of the Court of Claims to the Supreme Court of the United States.