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Christian Doctrine Applied to Subcontract

Client Alert | 1 min read | 04.05.13

As discussed in more detail in a Crowell Alert issued today, the U.S. District Court for D.C. in UPMC Braddock v. Harris (Mar. 30, 2013) relied on the Christrian doctrine, a rule derived from case law that allows for the inclusion in a contract by operation of law of omitted government contract clauses expressing a significant public procurement policy, to incorporate affirmative action clauses into a subcontract between certain hospitals and a managed care organization with a Federal Employees Health Benefits Program prime contract. This is the first instance of which we are aware that a court has used the Christian doctrine to incorporate federal procurement obligations into a subcontract.


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Client Alert | 2 min read | 12.19.25

GAO Cautions Agencies—Over-Redact at Your Own Peril

Bid protest practitioners in recent years have witnessed agencies’ increasing efforts to limit the production of documents and information in response to Government Accountability Office (GAO) bid protests—often will little pushback from GAO. This practice has underscored the notable difference in the scope of bid protest records before GAO versus the Court of Federal Claims. However, in Tiger Natural Gas, Inc., B-423744, Dec. 10, 2025, 2025 CPD ¶ __, GAO made clear that there are limits to the scope of redactions, and GAO will sustain a protest where there is insufficient evidence that the agency’s actions were reasonable....