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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.

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Client Alert | 7 min read | 12.17.25

CARB Proposes Regulations Implementing California GHG Emissions and Climate-Related Financial Risk Reporting Laws

After hosting a series of workshops and issuing multiple rounds of materials, including enforcement notices, checklists, templates, and other guidance, the California Air Resources Board (CARB) has proposed regulations to implement the Climate Corporate Data Accountability Act (SB 253) and the Climate-Related Financial Risk Act (SB 261) (both as amended by SB 219), which require large U.S.-based businesses operating in California to disclose greenhouse gas (GHG) emissions and climate-related risks. CARB also published a Notice of Public Hearing and an Initial Statement of Reasons along with the proposed regulations. While CARB’s final rules were statutorily required to be promulgated by July 1, 2025, these are still just proposals. CARB’s proposed rules largely track earlier guidance regarding how CARB intends to define compliance obligations, exemptions, and key deadlines, and establish fee programs to fund regulatory operations....

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