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Christian Doctrine Applied to Subcontract

Client Alert | 1 min read | 04.05.13

As discussed in more detail in a Crowell Alert issued today, the U.S. District Court for D.C. in UPMC Braddock v. Harris (Mar. 30, 2013) relied on the Christrian doctrine, a rule derived from case law that allows for the inclusion in a contract by operation of law of omitted government contract clauses expressing a significant public procurement policy, to incorporate affirmative action clauses into a subcontract between certain hospitals and a managed care organization with a Federal Employees Health Benefits Program prime contract. This is the first instance of which we are aware that a court has used the Christian doctrine to incorporate federal procurement obligations into a subcontract.


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Client Alert | 4 min read | 12.31.25

Raising the Bar: New York Expands Consumer Protection Law with FAIR Business Practices Act

New York Governor Kathy Hochul has signed into law the most significant update to New York’s consumer protection law in 45 years — the Fostering Affordability and Integrity through Reasonable Business Practices Act, or FAIR Business Practices Act — expanding the scope of the state’s authority to now challenge unfair and abusive business practices. The measure, backed by New York Attorney General (“AG”) Letitia James and signed on December 19, 2025, amends New York’s General Business Law § 349, giving regulators new tools to protect consumers and promote fair marketplace practices....