Army v. Blue Fox, Inc

In Army v. Blue Fox, Inc., 525 U.S. 255, 119 S. Ct. 687 (1999), a prime contractor on a government contract failed to pay a subcontractor, who then sued the Army seeking an equitable lien on any funds available or appropriated for the project and an order directing payment of those funds. The Supreme Court held that, since the subcontractor's claim for specific relief was against the defaulting prime contractor, an equitable lien represented compensatory or substitute relief, thus money damages. See id. at 692.