State Slammed For Adopting GAO Recommendation
Client Alert | less than 1 min read | 08.22.07
In Grunley Walsh Int'l v. U.S. (Fed. Cl. Aug. 3, 2007), in which Crowell & Moring represented the successful plaintiff, the Court of Federal Claims held that the Department of State acted arbitrarily when it adopted a GAO recommendation to reverse its own, longstanding interpretation of the total business volume requirement in the Diplomatic Construction Program statute (22 U.S.C. § 4852). The government argued that the court must defer to State's revised interpretation, but the Court refused to do so, because that would "effectively strip this court of any real review in any case where the agency followed a recommendation of the GAO on an interpretation of a statute or regulation."
Contacts
Insights
Client Alert | 6 min read | 11.25.25
Brussels Court Clarifies the EU’s SPC Manufacturing Waiver Regulation Rules
On November 13, 2025, the president of the French-speaking Brussels Enterprise Court ruled in the long-running battle between Sandoz and Regeneron about the correct interpretation of the EU’s Supplementary Protection Certificate (SPC) Manufacturing Waiver Regulation regarding exports to a non-EU market. The Brussels Court dismissed Regeneron’s claim that Sandoz had provided a defective notification and agreed with Sandoz’s interpretation of the Regulation.
Client Alert | 3 min read | 11.24.25
Client Alert | 7 min read | 11.24.25
Draft Executive Order Seeks to Short-Circuit AI State Regulation
Client Alert | 5 min read | 11.24.25
Qatar Enacts Law No. (22) of 2025 on Persons with Disabilities
