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Inadequate Documentation Dooms Cost Realism Evaluation

Client Alert | less than 1 min read | 02.14.12

In TriCenturion, Inc.; SafeGuard Services, LLC (Jan. 25, 2012), a case in which C&M represented one of the protesters, GAO sustained challenges to the agency’s determination that the awardee’s proposed labor costs were realistic in light of its technical approach, finding that the “inadequate” and “apparently incomplete” evaluation record, which the agency was unable to bolster through hearing testimony, failed to support the agency’s conclusions.  GAO also sustained challenges to the agency’s technical and past performance evaluations.

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Client Alert | 2 min read | 04.16.26

Federal Circuit Holds Challengers to CICA Stay Overrides Need Not Satisfy Four-Factor Injunctive Relief Test

In a significant decision for government contractors, on April 15, 2026, in Life Science Logistics, LLC v. United States, the U.S. Court of Appeals for the Federal Circuit held that bid protesters challenging an agency’s override of an automatic stay of contract performance under the Competition in Contracting Act (CICA) need not satisfy the demanding four-factor test traditionally required for preliminary injunctive relief.  In so doing, the Federal Circuit clarified that CICA stay override challenges need only demonstrate that the override decision was arbitrary and capricious—nothing more....