COFC Reverses Another Cica Stay Override
Client Alert | 1 min read | 05.10.04
Although the protester’s incumbent contract (and the 6-month extension) had expired, in Keeton Corrections, Inc. v. U.S., (March 17, 2004), the Court of Federal Claims rejected as arbitrary and capricious an override decision that was premised on the purported necessity of using the awarded contract to deliver necessary correctional services to the Bureau of Prisons. The court found that the agency had not explained why sole source purchase orders could not be used to obtain the necessary services pending GAO’s protest decision, and held that such sole source orders (issued either to the protester or the awardee) would be permissible under the circumstances, and would be less harmful to competition than an override of the CICA stay.
Insights
Client Alert | 3 min read | 03.12.26
DOJ Releases First-Ever Department-Wide Corporate Enforcement and Voluntary Self-Disclosure Policy
On March 10, 2026, the Department of Justice released the first-ever Department-wide Corporate Enforcement and Voluntary Self-Disclosure Policy (the “Department-wide CEP” or “Policy”), which applies to all non-antitrust corporate criminal cases across the Department. The new policy has been anticipated since December 2025, when Deputy Attorney General Todd Blanche announced the Department’s plans to release a new, single corporate enforcement policy for all criminal matters. According to the Department, the new policy is designed to “help ensure consistency across the Department” and “transparently describe the Department’s policies and decisionmaking.”
Client Alert | 3 min read | 03.12.26
Client Alert | 2 min read | 03.11.26
