Featured Chrome Extensions:

Casey IRACs are produced by an AI that analyzes the opinion’s content to construct its analysis. While we strive for accuracy, the output may not be flawless. For a complete and precise understanding, please refer to the linked opinions above.

Keywords

contractplaintiffliabilitystatuteprecedentmotioncontractual obligationmotion to dismiss
contractplaintiffdefendantliabilitystatuteprecedentappealmotioncontractual obligation

Related Cases

Rigby v. Philip Morris USA Inc., 717 Fed.Appx. 834
View Case »
Rigby v. Philip Morris USA Inc., 717 Fed.Appx. 834
View Case »
White v. United Steelworkers of America, AFL-CIO, Not Reported in F.Supp., 1963 WL 65912, 7 Fed.R.Serv.2d 363
View Case »
Carruth v. Superior Court, 80 Cal.App.3d 215, 145 Cal.Rptr. 344, 12 A.L.R.4th 1269
View Case »
Caterpillar Inc. v. Lewis, 519 U.S. 61, 117 S.Ct. 467, 136 L.Ed.2d 437, 65 USLW 4021, 96 FCDR 4350, 96 Cal. Daily Op. Serv. 8880, 96 CJ C.A.R. 1992, 10 Fla. L. Weekly Fed. S 211
View Case »
Justia Law Link
LexisNexis Link
Westlaw Link
CourtListener Link
Oyez Link

Prairie County, Montana v. United States, 113 Fed.Cl. 194

Facts

Plaintiffs Prairie County and Greenlee County sought to recover payments under the PILT, claiming they were owed money due to shortfalls in appropriated funds for fiscal years 2006 and 2007. Greenlee County had previously attempted to recover similar payments but was unsuccessful in both the Court of Federal Claims and the Federal Circuit. The government moved to dismiss the current action, arguing that the prior ruling precluded the counties from relitigating the issue.

Plaintiffs Prairie County, Montana and Greenlee County, Arizona seek to recover monies that they claim are due to them under the Payment in Lieu of Taxes Act (“PILT”), 31 U.S.C. §§ 6901 – 6907 (2000). Greenlee County previously was unsuccessful in seeking payments under the statute before the United States Court of Federal Claims (“Court of Federal Claims”) and the United States Court of Appeals for the Federal Circuit (“Federal Circuit”). Defendant moves to dismiss this action based on the earlier decision of the Federal Circuit.

Issue

Whether the counties could recover unpaid PILT amounts despite previous rulings and whether the government's liability under PILT is limited to appropriated funds.

Whether the counties could recover unpaid PILT amounts despite previous rulings and whether the government's liability under PILT is limited to appropriated funds.

Rule

The government's liability for PILT payments is limited to amounts appropriated by Congress, and the existence of an implied-in-fact contract must be established by demonstrating mutuality of intent, consideration, and other contract elements.

The Government's liability for payments to the counties under PILT was limited to the amounts appropriated by Congress; counties failed to establish the existence of an implied-in-fact contract; and county that previously was unsuccessful in seeking payments under the statute before the Court of Federal Claims and the Federal Circuit was precluded from relitigating the PILT payment deficiencies.

Analysis

The court applied the rule by referencing the precedent set in Greenlee County v. United States, which established that the PILT program is a benefits program rather than a contractual obligation. The court found that the plaintiffs failed to demonstrate the existence of an implied-in-fact contract and that the prior ruling precluded them from claiming unpaid amounts.

The court applied the rule by referencing the precedent set in Greenlee County v. United States, which established that the PILT program is a benefits program rather than a contractual obligation. The court found that the plaintiffs failed to demonstrate the existence of an implied-in-fact contract and that the prior ruling precluded them from claiming unpaid amounts.

Conclusion

The court granted the government's motion to dismiss, concluding that the plaintiffs failed to state a claim upon which relief could be granted.

Motion granted.

Who won?

The United States prevailed in the case because the court found that the plaintiffs could not establish a claim for relief under the PILT due to prior rulings and the limitations of the statute.

The United States prevailed in the case because the court found that the plaintiffs could not establish a claim for relief under the PILT due to prior rulings and the limitations of the statute.

You must be