United States Court of Appeals 

for the Federal Circuit ______________________

P.K. MANAGEMENT GROUP, INC.,

Appellant

v.

SECRETARY OF HOUSING AND URBAN 

DEVELOPMENT,

Appellee

______________________

2020-1260

______________________

Appeal from the Civilian Board of Contract Appeals in 

No. 6185, Administrative Judge Kyle E. Chadwick, Administrative Judge Allan H. Goodman, Administrative Judge 

Beverly M. Russell.

______________________

Decided: February 4, 2021

______________________

NICHOLAS SOLOSKY, Fox Rothschild LLP, Washington, 

DC, argued for appellant. Also represented by DOUGLAS 

HIBSHMAN, RONNI TWO.

 GEOFFREY MARTIN LONG, Commercial Litigation 

Branch, Civil Division, United States Department of Justice, Washington, DC, argued for appellee. Also represented by JEFFREY B. CLARK, MARTIN F. HOCKEY, JR.,

ROBERT EDWARD KIRSCHMAN, JR.; JONATHAN ENGLISH, 

Case: 20-1260 Document: 40 Page: 1 Filed: 02/04/2021
2 P.K. MANAGEMENT GROUP, INC. v. HUD

Office of General Counsel, United States Department of 

Housing and Urban Development, Washington, DC.

 ______________________

Before PROST, Chief Judge, LOURIE and HUGHES, Circuit 

Judges.

HUGHES, Circuit Judge.

P.K. Management Group, Inc. appeals a Civilian Board 

of Contract Appeals decision denying its claim that it 

should receive individual payments for inspections of Custodial properties under a contract with the Department of 

Housing and Urban Development. Because we agree with 

the Board’s determination that the contract terms unambiguously cover routine inspections through a monthly fee 

rather than individual payments, we affirm.

I

Under contract DU204SA-14-D-06 with HUD (the Contract), P.K. Management Group (PKMG) manages multiple

types of properties in HUD’s possession, including “HUDOwned Vacant” properties and “Custodial” properties. 

HUD-Owned properties are those that “HUD owns,”

J.A. 139, while Custodial properties are those of which 

HUD has taken possession but does not yet have title, 

J.A. 143–44. 

The Contract requires PKMG to perform various services related to the properties. For example, for each relevant property that comes into HUD’s possession, PKMG 

must perform an initial inspection and some initial services 

maintaining the property. As HUD’s possession of the property continues, PKMG must conduct ongoing management 

of the property. The specifics of ongoing management vary 

by property type. HUD does not own Custodial properties, 

so they are “not marketable” and have “limited property 

management tasks.” Id. Relevant here, PKMG must perform bi-weekly inspections of each property type. See

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P.K. MANAGEMENT GROUP, INC. v. HUD 3

J.A. 163, 171. These inspections are more thorough for 

HUD-Owned properties because HUD-Owned properties 

must be in “Ready to Show Condition,” while Custodial 

properties generally do not need to be ready for showing. 

Compare J.A. 163, with J.A. 171.

The Contract lists the compensation for each contractual service in a series of Contract Line Item Numbers 

(CLINs). The Contract requires HUD to pay “as full compensation for all work required, performed and accepted 

under [the] contract, inclusive of all costs and expenses, the 

fixed-unit-rate for the applicable CLINs and applicable periods, as stated in Part I, Section B of [the] contract.” 

J.A. 191. The contract requires some services to be compensated individually, while others are covered under monthly 

fees.

The issue here is which CLIN specifies the compensation for routine, bi-weekly inspections of Custodial properties. 

At first, HUD paid PKMG individually for every biweekly inspection, applying the per-inspection fee from 

CLIN 0005AA regardless of property type. Later, HUD began rejecting invoices for inspections of Custodial properties and only providing individual payments for HUDOwned properties. P.K. Mgmt. Grp., Inc. v. HUD, 2019 

CIVBCA Lexis 208, *5 (Aug. 20, 2019). PKMG submitted a 

claim to the HUD contracting officer seeking a determination that PKMG is entitled to CLIN 0005AA fees for inspections of Custodial properties. Id. The officer denied the 

claim, stating that “the contract is clear that CLIN 0005AA 

applies to HUD-Owned Vacant Properties only.” Id. at *5–

6. The officer explained the prior payments by noting that 

HUD’s payment system “was erroneously programmed” to 

pay for each inspection individually, and that the change 

in behavior did not signal a change in interpretation. Id. at 

*6. PKMG appealed to the Board, which denied the appeal, 

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4 P.K. MANAGEMENT GROUP, INC. v. HUD

deeming the Contract language unambiguous. See id. at 

*6–14. PKMG now appeals to this court.

II

Pursuant to the Contract Disputes Act, 41 U.S.C. 

§ 7107(b)(1), we review the Board’s decisions on questions 

of law de novo. Dai Glob. v. Adm’r of the United States 

Agency for Int'l Dev., 945 F.3d 1196, 1198 (Fed. Cir. 2019). 

However, “we give the Board’s interpretation of government contracts careful consideration given its considerable 

experience and expertise.” Agility Logistics Servs. Co. KSC 

v. Mattis, 887 F.3d 1143, 1148 (Fed. Cir. 2018). Contractual 

interpretation is a pure legal issue. 

PKMG argues that CLIN 0005AA requires HUD to pay 

individually for each inspection of Custodial properties.

However, for the following reasons, we hold that the plain 

meaning of the contract is that CLIN 0006 covers these inspections through a monthly fee.

First, the title of CLIN 0005AA indicates that it applies 

only to HUD-Owned properties. CLIN 0005AA is entitled 

“On-Going Property Inspection HUD-Owned Vacant.” J.A. 

278. Although Custodial properties are in HUD’s possession, they are not owned by HUD. See J.A. 143 (noting that 

for Custodial properties, “[t]itle is not yet in HUD’s 

name.”). Thus, as the Board noted, “[i]n order to accept 

PKMG’s position that CLIN 0005AA sets the unit price of 

inspections of custodial properties, we would need to read 

the words ‘HUD-owned vacant’ out of CLIN 0005AA . . . .” 

P.K. Mgmt. Grp., Inc., 2019 CIVBCA Lexis 208, at *10. “An 

interpretation that gives meaning to all parts of the contract is to be preferred over one that leaves a portion of the 

contract useless, inexplicable, void, or superfluous.” NVT 

Techs., Inc. v. United States, 370 F.3d 1153, 1159 (Fed. Cir. 

2004) (citing Gould, Inc. v. United States, 935 F.2d 1271, 

1274 (Fed. Cir. 1991)). PKMG’s argument would make the 

title of CLIN 0005AA inexplicable. 

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P.K. MANAGEMENT GROUP, INC. v. HUD 5

Another indication that CLIN 0005AA only applies to 

HUD-Owned Vacant properties is its connection with

CLIN 0005. Neither party disputes that CLIN 0005 (entitled “On-Going Property Management (PM) Fee, HUDOwned Vacant”) applies only to HUD-Owned vacant properties, and the two CLINs are linked by both their numbering and titles. See P.K. Mgmt. Grp., Inc., 2019 CIVBCA 

Lexis 208, at *4. Thus, the Board called CLIN 0005AA a 

“sub-CLIN” of CLIN 0005. Id. at *9. PKMG disputes this

“sub-CLIN” characterization because “sub-CLIN” isn’t a 

term in the Contract, but regardless, the most sensible interpretation is that provisions with related numbering apply to the same properties, particularly when both have 

titles that say “HUD-Owned Vacant.” PKMG’s interpretation would require us to deem the CLIN numbering system

and titles meaningless. 

Only CLIN 0006 refers to Custodial properties, and we 

hold that this CLIN governs the compensation for routine 

inspections of Custodial properties. Entitled “Inspection, 

Initial Services, On-Going [Property Management] For 

Custodial Properties,” CLIN 0006 sets a monthly fee that 

covers a variety of services. J.A. 278. The parties do not 

dispute that all other services associated with Custodial 

properties are covered by this monthly fee, so it would be 

anomalous to interpret this one service, routine inspections 

of Custodial properties, to be covered by a separate provision, which by its title only addresses fees for HUD-Owned 

properties. Thus, we agree with the Board that “the fixed 

monthly price in CLIN 0006 includes inspections of custodial properties.” P.K. Mgmt. Grp., Inc., 2019 CIVBCA Lexis 

208, at *13. 

PKMG raises several arguments to the contrary, but 

we find none of them persuasive. PKMG contends that because one section of the Contract lays out criteria for receiving “credit” for routine inspections of Custodial 

properties, the inspections must be individually compensated. See Appellant’s Br. 16 (citing J.A. 163–64). But 

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6 P.K. MANAGEMENT GROUP, INC. v. HUD

“credit” does not equate to payment. One can receive credit 

for a required task without being individually paid for that 

task. In another section, the Contract describes the consequences of the “failure of the Contractor to perform . . . any

routine inspection” under CLIN 0005AA. J.A. 125 (emphasis added). PKMG argues that the use of the word “any” 

here indicates that CLIN 0005AA deals with all routine inspections, not just those of HUD-Owned properties. Appellant’s Br. 12–13. But a more reasonable interpretation is 

that, to the extent this passage discusses CLIN 0005AA, it

simply refers to any routine inspection under 

CLIN 0005AA, i.e., any inspection of a HUD-Owned property. 

Reading the Contract as a whole, we hold that the plain 

meaning places compensation for routine inspections of 

Custodial properties under CLIN 0006 rather than 

CLIN 0005AA. Because the Contract is unambiguous, we 

follow the plain meaning without considering extrinsic evidence or related arguments. Nw. Title Agency, Inc. v. 

United States, 855 F.3d 1344, 1347 (Fed. Cir. 2017) (citing 

Coast Fed. Bank, FSB v. United States, 323 F.3d 1035, 

1040 (Fed. Cir. 2003) (en banc)).

III

We have considered PKMG’s remaining arguments 

and find them unpersuasive. Because we agree with the 

Board that CLIN 0006, rather than CLIN 0005AA, governs 

compensation for routine inspections of Custodial properties, we affirm.

AFFIRMED

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