On Human Bondage and Christian Doctrine

To be clear, the bondage here is the bond requirement under Federal construction contracts, and the doctrine does not appear in the catechism but in the Court of Claims’ old decision in G. L. Christian & Associates v. United States, 312 F.2d 418 (Ct. Cl. 1963).  In K-Con, Inc. v. Secretary of the Army, the Court of Appeals for the Federal Circuit recently applied the Christian doctrine to read bonding requirements into construction contracts that lacked them. The decision is not particularly surprising but is a useful reminder that you may have contract requirements that don’t actually appear anywhere in your contract.

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