1. Home
  2. |Insights
  3. |Strong Mitigating Factors Trump Debarment

Strong Mitigating Factors Trump Debarment

Client Alert | less than 1 min read | 07.30.07

In Canales v. Paulson (D.D.C. July 16, 2007, https://ecf.dcd.uscourts.gov/cgi-bin/show_public_doc?2006cv1330-47), the federal district court overturned a Treasury Department debarment from government contracting on the ground that the debarring official did not explain reasons for debarment in the face of strong mitigating factors (spotless record before the offense; five years since the incident; extensive business with the government in the interim; misdemeanor conviction) presented to him at the debarment proceeding.

Insights

Client Alert | 4 min read | 04.23.26

Bipartisan Coalition of State AGs Backs Federal PBM Transparency Rule

In mid-April, a bipartisan coalition of 45 State Attorneys General (AG) submitted a formal letter to the U.S. Department of Labor (DOL) expressing their collective support for a proposed rule (Improving Transparency into Pharmacy Benefit Manager Fee Disclosure, or RIN 1210-AB37), which would — if enacted — impose new disclosure obligations on pharmacy benefit managers (PBM) regulated under the Employee Retirement Income Security Act of 1974 (ERISA)....