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."
Contacts
Insights
Client Alert | 5 min read | 06.05.26
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).
Client Alert | 5 min read | 06.04.26
EU Pay Transparency Directive: The Transposition Deadline is Looming — What Now?
Client Alert | 4 min read | 06.04.26
Surveillance Pricing Update: California’s Sweeping AB 2564 Passes Assembly and Heads to Senate
Client Alert | 4 min read | 06.04.26
USTR Proposes Sweeping Tariffs as Part of Section 301 Forced Labor Import Enforcement Investigation


