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ASBCA Holds that Transmission Emails are "Part of the Same Transaction" as Mods for Plain Meaning Purposes

Client Alert | 1 min read | 05.24.19

Can contractors reserve rights in a transmission email while executing a contract modification that is silent on such reservation? The ASBCA recently affirmed again that yes, contractors can. In NMS Management, Inc., ASBCA No. 61519 (Apr. 11, 2019), a dispute over the “improper attempt at a partial exercise” of an option period, the ASBCA rejected the Government’s argument that NMS was strictly bound by the terms of a signed bilateral modification – viewed in isolation – because NMS’s accompanying transmission email stated that it was signing under protest. The ASBCA clarified the plain meaning rule by citing precedent that the “interpretation of a contract as a whole requires consideration of all documents that are part of the same transaction together.” The Board held that “the [transmission] email dispels any notion that Modification No. P00011 is the only writing to consider when evaluating the legal consequences of the modification.”

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Client Alert | 4 min read | 03.05.26

DOL’s Proposed Independent Contractor Rule Reverts to Prioritize Two Core Factors – Likely Limiting Misclassification Claims by Contractors

The U.S. Department of Labor (DOL) has proposed another revision to independent contractor regulations, one that would provide for more leeway in classifying workers as contractors. DOL’s proposed rule, published on February 26, 2026, would rescind the Biden DOL’s March 2024 independent contractor regulation and reinstate a framework substantially tracking the prior Trump rule of January 2021. The proposed rule would also apply the narrower analysis to worker classifications under the Family and Medical Leave Act (FMLA) and the Migrant and Seasonal Agricultural Worker Protection Act (MSPA). The comment period closes in late April 2026; until then, the 2024 rule remains in effect for purposes of private litigation....