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Arbitrary and Capricious

Davis Wright Tremaine LLP

ASBCA Reaffirms That Contractors May Recover Damages for Arbitrary CPAR Ratings Issued by the Government

The U.S. Armed Services Board of Contract Appeals recently addressed whether a contractor is entitled to the recovery of monetary damages arising from a negative CPAR rating issued by the government. The Board's decision in...more

Mayer Brown Free Writings + Perspectives

Fifth Circuit Remands SEC Securities Lending and Short Sale Rules for Further Economic Analysis

On August 25, 2025, the United States Court of Appeals for the Fifth Circuit issued an opinion in National Association of Private Fund Managers v. SEC addressing Securities and Exchange Commission (SEC or the “Commission”)...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Startup/Shutdown/Malfunction/Clean Air Act: Federal Appellate Court Upholds Title V Affirmative Defense

The United States Court of Appeals District of Columbia Circuit (“Court”) addressed in a September 5th Opinion the validity of the Clean Air Act Startup/Shutdown/Malfunction (“SSM”) affirmative defense. See SSM Litigation...more

Fox Rothschild LLP

The Bat Flip Heard Around the World: Rocco v. Little League Baseball, Inc.

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In the world of youth sports, few moments are as exhilarating as a home run in a championship game. For 12-year-old M.R. of Haddonfield, New Jersey, that moment became the center of a legal controversy that captured national...more

Bradley Arant Boult Cummings LLP

Earmuffs, Kids: The Federal Circuit Delivers the F-bomb Right Back to the TTAB

The Federal Circuit’s recent precedential decision in In re Erik Brunetti has surely raised some eyebrows in the trademark community (and beyond), not just for its subject matter (the attempted registration of a certain...more

Pillsbury - Bid Protest Debrief

“Consistently Inconsistent”: Court of Federal Claims Finds Navy’s Past Performance Rating System Arbitrary

In Advanced Technology Systems Company v. United States, U.S. Court of Federal Claims, No. 25-515C (July 16, 2025), Advanced Technology Systems Company (ATSC) protested the Navy’s award of a contract for a nationwide maritime...more

King & Spalding

Court in Northern District of Texas Finds Elevance Health’s Drop in Ratings Proper

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On August 18, 2025, the United States District Court for the Northern District of Texas denied Plaintiff Elevance Health’s (“Elevance”) motion for summary judgment against HHS and CMS. Elevance’s lawsuit alleges that HHS and...more

Holland & Knight LLP

CFPB Seeks Comments and Data on Revised Open Banking Rule

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The CFPB published an advanced notice of proposed rulemaking (ANPR) on Aug. 22, 2025, seeking comments and data to aid in the agency's reconsideration of its Section 1033 Open Banking Rule. This notice follows the CFPB's...more

Perkins Coie

Cumulative Impacts Analysis of Forest Thinning Project Inadequate Under NEPA

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The Ninth Circuit held that the Forest Service’s substantial reduction of a forest thinning project between the Draft and Final EAs did not require repeating the public comment process or considering new alternatives under...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Southern Pinesnake/Endangered Species Act: Center for Biological Diversity Judicial Action Filed Challenging U.S. Fish and...

The Center for Biological Diversity (“CBD”) filed in the United States District Court for the District of Columbia a Complaint for Declaratory and Injunctive Relief (“Complaint”) against the United States Fish and Wildlife...more

Ballard Spahr LLP

Community Groups File Lawsuit Seeking to Force CFPB to Implement the Section 1071 Rule

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The saga of the CFPB’s section 1071 small business data collection and reporting rule continues. Rise Economy, fka California Reinvestment Coalition (Rise), the National Reinvestment Coalition (NCRC), the Main Street Alliance...more

Perkins Coie

Failure to Explain Selection of Project Alternative Violated NEPA and APA

Perkins Coie on

The Ninth Circuit held that the Bureau of Land Management (BLM) acted arbitrarily and capriciously by failing to explain in its Record of Decision why it selected a project alternative that did not meet the development...more

Fox Rothschild LLP

Other Transaction Authority: COFC Employs a “Principal Purpose” Test to Determine Whether Bid Protest Jurisdiction Exists

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Much has been written during recent years regarding the increasing volume of government acquisitions and spending effected under Other Transaction (OT) authority. These transactions are generally exempt from the requirements...more

Lowenstein Sandler LLP

Recoverability of State Response Costs to Be Determined Under an Arbitrary and Capricious Standard of Review Limited to the...

Lowenstein Sandler LLP on

On May 30, the United States District Court for the Central District of California determined that judicial review of whether state response costs are recoverable under Section 107(a)(4)(A) of the Comprehensive Environmental...more

WilmerHale

Limits of IEEPA’s Designation Authority

WilmerHale on

Over the first 100 days and beyond, the Trump Administration has deployed national security authorities in novel ways. Perhaps most notably, President Trump has asserted authority under the International Emergency Economic...more

Quarles & Brady LLP

Back to the Future: What a Recent Vacatur, Executive Order, and Dear Colleague Letter Mean for Title IX Compliance

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Within the last month, three developments have rocked the Title IX world: the Eastern District of Kentucky’s decision in State of Tennessee v. Cardona, President Trump’s Executive Order restricting the federal definition of...more

Troutman Pepper Locke

Supreme Court Weighs Vape Venue Dispute

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On January 21, the Supreme Court heard arguments in a case addressing who may challenge Food and Drug Administration (FDA) marketing denial orders for new tobacco products....more

Troutman Pepper Locke

Federal Appellate Court Agrees that FDA Cannot Regulate “Premium Cigars”

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Yet again, the premium cigar industry has prevailed in federal court against the U.S. Food and Drug Administration (FDA). FDA appealed a federal district court decision vacating its rule (the Deeming Rule) subjecting premium...more

Bradley Arant Boult Cummings LLP

Biden’s Executive Order on Project Labor Agreements Violates CICA

In a recent decision, the Court of Federal Claims (COFC) ruled on bid protests filed by 12 construction companies challenging the implementation of a February 4, 2022, Executive Order 14063 that mandated the use of project...more

Troutman Pepper Locke

Fifth Circuit Vacates FTC’s CARS Rule

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Yesterday, the U.S. Court of Appeals for the Fifth Circuit issued a significant opinion vacating the Federal Trade Commission’s (FTC) Combating Auto Retail Scams Trade Regulation Rule (CARS Rule). The decision came in...more

Husch Blackwell LLP

Federal District Court Vacates 2024 Title IX Regs

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On January 9, 2025, the U.S. District Court for the Eastern District of Kentucky vacated the Biden administration’s 2024 Title IX regulations. The vacatur applies nationwide, meaning the 2020 Title IX final rule and Title IX...more

Bowditch & Dewey

Court Vacates 2024 Title IX Regulations—Next Steps for Higher Education Institutions

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On January 9, 2025, the United States District Court for the Eastern District of Kentucky (the “Court”) issued a decision and order in Tennessee v. Cardona (the “January 9 Order”). Plaintiffs had sued the Department of...more

Fisher Phillips

Federal Court Blocks Sweeping Title IX Rule for Schools Nationwide: How Your School Can Approach the Changes

Fisher Phillips on

A federal court just blocked the sweeping Title IX rule finalized by the Biden administration last year – effectively wiping the entire rule off the books for all schools nationwide. Prior to Thursday’s ruling, schools across...more

Pullman & Comley - School Law

Kentucky Federal Court Vacates the 2024 Title IX Regulations in Their Entirety

The Federal District Court of Kentucky just issued a sweeping ruling vacating the 2024 Title IX Regulations that went into effect on August 1, 2024.  The case, State of Tennessee v. Miguel Cardona, is one of numerous cases...more

Stevens & Lee

FTC Files Opening Brief in Noncompete Rule Appeal

Stevens & Lee on

On Jan. 2, 2025, the Federal Trade Commission (FTC or Commission) filed its opening brief with the Fifth Circuit Court of Appeals in Ryan LLC et.al. v. Federal Trade Commission, the case in which the plaintiffs are...more

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