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Campanella & Cardi Construction Co. v. Commonwealth

Citations: 217 N.E.2d 925; 351 Mass. 184; 1966 Mass. LEXIS 630

Court: Massachusetts Supreme Judicial Court; June 16, 1966; Massachusetts; State Supreme Court

Narrative Opinion Summary

This case involves a series of petitions by a construction company seeking additional compensation from the Commonwealth's Department of Public Works for highway construction projects. The petitions were filed under G.L.c. 258, but the Commonwealth moved to abate these claims, arguing they were filed beyond the statutory three-year limitation period prescribed by G.L.c. 260.3A. The court upheld the Commonwealth’s motion, finding that the causes of action accrued prior to July 26, 1962, as the projects were completed and semi-final estimates issued by early 1962. The semi-final estimates, a practice aligned with G.L.c. 30.39G, were intended to ensure timely payments while allowing disputes to be resolved separately. The court concluded that the semi-final estimates signified acknowledgment of the work and triggered the obligation for payment, thus establishing the accrual dates for the claims. The court further determined that the potential for administrative settlement did not affect the statute of limitations. As a result, the court overruled the Commonwealth's exceptions, reinforcing the necessity for timely filings under the statutory framework.

Legal Issues Addressed

Accrual of Causes of Action

Application: The court held that the causes of action accrued no later than the issuance dates of the semi-final estimates, as these dates marked the Commonwealth's acknowledgment of completed work and payment obligations.

Reasoning: The court determined that the company's causes of action arose no later than the dates of the semi-final estimates when the work was completed and acknowledged, making the Commonwealth aware of its payment obligations.

Impact of Administrative Settlement on Statute of Limitations

Application: The court ruled that the potential for administrative settlement did not toll or suspend the running of the statute of limitations.

Reasoning: The possibility of an administrative settlement did not suspend the statute of limitations.

Role of Semi-Final Estimates under G.L.c. 30.39G

Application: The statutory provision for semi-final estimates was interpreted to ensure prompt payment to contractors while preserving the right to contest disputed items.

Reasoning: The semi-final estimate, established under St. 1955, c. 597 (G.L.c. 30, § 39G), aims to facilitate prompt payment to contractors.

Statute of Limitations under G.L.c. 260.3A

Application: The court applied the statutory three-year limitation period for filing claims against the Commonwealth, determining that the contractor's claims were time-barred as they accrued before July 26, 1962.

Reasoning: The Commonwealth responded with an abatement motion, claiming the petitions were filed beyond the three-year limitation set by G.L.c. 260.3A. The court upheld the abatement, establishing that the causes of action accrued prior to July 26, 1962.