DoD Memo Recalls 'Essential' Civilian Workers
Client Alert | 1 min read | 10.09.13
On October 5, Secretary Hagel issued guidance relating to DoD's implementation of the Pay Our Military Act (POMA), which passed just hours before the government "shutdown" at midnight on September 30 and provides for funding certain DoD functions while interim or full-year appropriations for FY 2014 are not in effect. The memo, crafted in consultation with DOJ, states that POMA permits funding for active duty military and civilian employees "whose responsibilities provide support to service members providing active service and their families" and "contribute to sustaining capabilities and Force Readiness" (a list which at least initially did not include DCAA auditors, CIO functions, or DCMO functions, although it appears that at least some auditors at some locations have been recalled) and permits expenditure of "such sums as are necessary to provide pay and allowances to contractors of DoD who[m] the Secretary determines are providing support to members of the Armed Forces in active service" (though the memo notes that DoD lawyers are still analyzing what that means).
Insights
Client Alert | 3 min read | 07.18.25
Eighth Circuit Cancels Click-to-Cancel
On July 8, 2025, the Eighth Circuit vacated the Federal Trade Commission’s (“FTC”) Negative Option Rule, also known as the Click-to-Cancel Rule, on procedural grounds. The Click-to-Cancel Rule, which provided a streamlined path for consumers to cancel subscription services in a few clicks of a mouse, was scheduled to take effect on July 14, 2025, but the Court found that the FTC had failed to follow mandatory procedural requirements.
Client Alert | 9 min read | 07.18.25
U.S. Lifts Most Sanctions on Syria in Major Policy Development
Client Alert | 6 min read | 07.17.25
Client Alert | 3 min read | 07.17.25
(Not the Funniest) Weekend Update: Recap of Recent Developments in the EU-US Tariff Dispute
