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Market Value is the Price of Holdover Tenancy

Client Alert | less than 1 min read | 10.12.10

A tenant has an implied duty to vacate at the end of the lease term and, when a contract does not specify the rate to apply, a holdover tenant must pay damages at the market lease rate. In J. Leonard Spodek, the PSBCA averaged the calculations of each party's expert appraisal after finding that one expert had understated and the other overstated the market rate.

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Client Alert | 3 min read | 07.10.26

Federal Circuit Clarifies Application of Blue & Gold: Proposal Submission Deadline, Not Award, is the Operative Time for Filing

In Utech, Inc. v. United States, No. 24-1586 (Fed. Cir. June 24, 2026), the U.S. Court of Appeals for the Federal Circuit clarified that in most cases, a pre-award protest must be filed before the proposal submission deadline to avoid the Blue & Gold waiver rule.  This decision, while nonprecedential, is in line with U.S. Government Accountability Office (GAO) precedent, which has long held that pre-award protests must be filed before the proposal submission deadline....