Davis-Bacon Violation Leads to FCA Liability
Client Alert | 1 min read | 10.16.12
On October 1, the Sixth Circuit in United States ex rel. Wall v. Circle C Constr., LLC, affirmed a decision imposing FCA liability when a prime had submitted inaccurate or false payroll certifications that did not properly describe work done by its subcontractors and that also contained hourly wages for subcontractor employees that did not meet federal guidelines for prevailing wages under the Davis-Bacon Act. This opinion serves as an important reminder to primes and subcontractors that failure to comply with minimum wage rate requirements may have significant adverse consequences and also suggests that companies that learn of such violations must carefully consider whether mandatory disclosure pursuant to FAR Subpart 9.4 or 52.203-13 is required.
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Client Alert | 2 min read | 12.29.25
FYI – GAO Finds Key Person “Available” Despite Accepting Employment with a Different Company
GAO’s key personnel rule is well-known—and often a source of frustration— amongst government contractors. Proposed key personnel who become “unavailable” prior to contract award—especially where they have accepted employment with a different company—may doom an offeror’s proposal by rendering it noncompliant with solicitation requirements. But GAO’s recent decision in FYI – For Your Information, Inc., B-423774, B-423774.2 (Dec. 19, 2025) provides some potential relief from that rule.
Client Alert | 4 min read | 12.29.25
More Than Math: How Desjardins Recognizes AI Innovations as Patent-Eligible Technology
Client Alert | 10 min read | 12.24.25
Client Alert | 3 min read | 12.24.25
Keeping it Real: FTC Targets Fake Reviews in First Consumer Review Rule
