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D.C. Circuit Creates Split over the Reach of the First-to-File Bar

Client Alert | 1 min read | 04.18.14

In U.S. ex rel. Shea v. Verizon Co., the D.C. Circuit held that (1) two complaints may be "related" even if they involve different agencies or contracts, (2) the bar applies even when the same relator filed the earlier action, and (3) it continues to operate even after the earlier-filed action is resolved. The third holding (which drew a dissent) conflicts with dicta from two other circuits and the Fourth Circuit's 2013 opinion in U.S. ex rel. Carter v. Halliburton Co., petition for cert. filed (discussed here), holding that the first-to-file bar only applies while the earlier action is still pending.

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Client Alert | 5 min read | 06.05.26

Grants Overhauled: What the Proposed Rewrite of 2 CFR Part 200 Means for Federal Financial Assistance Award Recipients

The Office of Management and Budget issued on May 29, 2026 a Proposed Rule that would significantly revise the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) at 2 C.F.R. Part 200, potentially impacting the full lifecycle of federal grants, cooperative agreements and other forms of financial assistance, from pre-award merit review through post-award administration and termination. These proposed changes are designed to implement the President’s policy priorities, executive actions related to diversity, equity and inclusion (DEI) activities, and Executive Order No. 14332, Improving Oversight of Federal Grantmaking (EO 14332)....