Federal Circuit Drops Bombshells on CDA Statute of Limitations and CAS "Materiality" Test
Client Alert | less than 1 min read | 12.11.14
In Sikorsky Aircraft Corp. v. U.S., the Federal Circuit upended the prevailing case law on the CDA statute of limitations by holding that the six-year SOL for filing CDA claims is "not jurisdictional" and "need not be addressed before deciding the merits." In denying the merits of the government's $80 million CAS 418 claim, the Federal Circuit also held that the cost of Sikorsky's management and supervision was "not a material amount of the total pool costs" because managers/supervisors comprised only 7 to 14 percent of the pertinent workforce, clarifying that materiality requires "a significant amount."
Insights
Client Alert | 2 min read | 07.01.25
DoD Establishes New DOGE Approval Process for ITC&MS and A&AS Contracts
On June 23, 2025, the DoD issued a memorandum, “Implementation of Department of Government Efficiency Cost Efficiency Initiative,” to establish a new DOGE approval process for unclassified IT consulting and management services (ITC&MS) contracts or task orders (TOs), and advisory and assistance services (A&AS) contracts or TOs. The memorandum establishes a formal approval process, which directs DOGE to review and provide input for certain contract requirement packages included in Defense Secretary Pete Hegseth’s May 27, 2025 directive, “Implementation of Executive Order 14222 – Department of Government Efficiency Cost Efficiency Initiative” (“Contract Guidance”).
Client Alert | 10 min read | 07.01.25
Ninth Circuit Decision Underscores Increasing False Claims Act Risks to U.S. Importers
Client Alert | 8 min read | 06.30.25
Client Alert | 3 min read | 06.30.25
