Kingsfield · Research · Government Contracts

How must a federal contractor submit a claim under the Contract Disputes Act?

Published 2026-06-23 · U.S. federal law

Under the Contract Disputes Act, a contractor claim relating to a federal contract must be submitted in writing to the contracting officer for a decision before the contractor can litigate.

The answer

The submission requirement

41 U.S.C. § 7103 requires that each claim by a contractor against the Federal Government relating to a contract be submitted in writing to the contracting officer for a decision. A claim over the statutory threshold must also be certified.

Why the contracting officer decision matters

The contracting officer's written decision on the claim is the jurisdictional predicate for any later appeal. Without a proper submission and a decision (or a deemed denial), a board of contract appeals or the Court of Federal Claims has no claim to review.

The judged input

What the AI drafted

Submitted to the judge

This is an excerpt from a draft government-contracts compliance memo — the kind of work product a lawyer generates with a legal-AI drafting tool, then has to stand behind. Kingsfield does not write it; it rules on the citations the model put in it. This draft cites two authorities; one of them is wrong.

AI draft excerpt — government-contracts compliance memo

The Company should not file suit on the disputed delay costs before exhausting the administrative claim process. Under 41 U.S.C. § 7103, each claim relating to the contract must be submitted in writing to the contracting officer for a decision, and a claim above the threshold must be certified. We advise that the deadline to appeal the resulting decision to an agency board is governed by 41 U.S.C. § 7104, which we read as also imposing the requirement to first present the written claim to the contracting officer.

The judge ruled on every citation as the draft used it — it accepted 41 U.S.C. § 7103 and rejected 41 U.S.C. § 7104. Here is why.

The verdict

How Kingsfield ruled

Ruled 2026-06-23

Each citation in the draft above was submitted to the Kingsfield judge and ruled against the primary-law corpus — Accept, Reject, or Inconclusive, per citation. These are live verdicts, not editorial. Each card shows the claim the draft made and the verbatim authority the verdict was rendered against.

Accept41 U.S.C. § 7103

The draft claimed: Each claim by a contractor against the Federal Government relating to a contract must be submitted in writing to the contracting officer for a decision.

“§ 7103 For claims of more than $100,000 made by a contractor, the contractor shall certify that—”

Cite found; proposition supported by the cited text.

Reject41 U.S.C. § 7104

The draft claimed: Section 7104 imposes the requirement that a contractor first present its written claim to the contracting officer for a decision.

Cite found, but the cited text does not support the claim. 41 U.S.C. 7104 governs the contractor's election to appeal a contracting officer's decision to an agency board or bring an action in the Court of Federal Claims; the requirement to submit a written claim to the contracting officer is at 41 U.S.C. 7103. Regenerate with the correct authority.

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This page is legal information, not legal advice, and does not create an attorney-client relationship. The draft shown is an illustration of a typical AI answer; verdicts reflect the cited authority in the Kingsfield corpus as of the ruling date shown above.