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Following GAO Recommendation Doesn't Insulate Agency's Action After Protest

Client Alert | less than 1 min read | 08.18.11

The Federal Circuit in Turner Constr. Co. v. U.S. held that the Army should not have followed the recommendation of a GAO bid protest decision to disqualify an awardee based upon alleged organizational conflicts of interest ("OCIs") because the GAO decision failed to identify "hard facts" supporting the existence of an OCI and, therefore, "lacked a rational basis." Upholding the CFC decision and citing that court's authority to "award any relief that [it] considers proper," the Federal Circuit also let stand an order enjoining reprocurement and reinstating the awardee's contract, which the Army had terminated in response to the GAO decision.

Insights

Client Alert | 4 min read | 09.02.26

The CSC Is Investigating: What Its New NIL Enforcement Memo Means for Institutions

On August 20, 2026, the College Sports Commission (CSC) released a memorandum outlining how its Department of Investigations (DOI) is approaching enforcement of name, image, and likeness (NIL); revenue sharing; and roster limit rules. The memo signals that the CSC’s enforcement apparatus is fully operational and that Division I institutions should prepare for direct investigative engagement....