Locke v. United States
United States Court of Claims
283 F.2d 521 (1960)
Locke (plaintiff) ran a typewriter repair business awarded a spot on a GSA Schedule requirements contract, alongside three other vendors, under which certain federal agencies were required to use one of these four vendors for typewriter repair, choosing among them as they saw fit. After operating under the contract for several months and receiving some business, Locke's contract was terminated for default and his business removed from the GSA Schedule; a Board of Review found the termination improper but denied damages, reasoning they couldn't be properly determined, and Locke appealed to the Court of Claims.
Whether, when a reasonable probability of contract-breach damages can be clearly established, uncertainty as to the exact amount precludes recovery.