When an agency conducts a multiple-award indefinite delivery, indefinite quantity (IDIQ) competition, successful awardees often wonder whether they can protest the agency’s award to other companies at the U.S. Court of Federal Claims. For over a decade, the answer has been a murky “maybe” with various Court of Federal Claims decisions divided over the issue. But in a precedential September 16, 2026, decision, the U.S. Court of Appeals for the Federal Circuit in Island Creek Associates, LLC v. United States resolved this split, holding that IDIQ contract awardees lack standing to challenge the IDIQ awards to fellow competitors.
Continue Reading Federal Circuit Resolves Court Split Over IDIQ Awardee Standing
Christian Curran
Christian N. Curran is a partner in Crowell & Moring’s Washington, D.C. office, where he practices in the Government Contracts Group. His practice focuses on government contracts litigation and counseling, including bid protests, government investigations, and compliance with federal and state procurement laws and regulations.
Christian has broad experience in the government contracts arena, including bid protest litigation at both the Government Accountability Office and the Court of Federal Claims, contract claims before the Armed Services Board of Contract Appeals, prime-sub disputes, internal investigations, mandatory disclosures, transactional due diligence, Defense Contract Audit Agency audits, and compliance assessments. He also has experience in both traditional litigation and alternative dispute resolution forums, including international arbitration and mediation, and administrative proceedings before various government agencies.
All Things Protest: Blue & Gold and Late is Late
Crowell & Moring’s “All Things Protest” podcast keeps you up to date on major trends in bid protest litigation, key developments in high-profile cases, and best practices in state and federal procurement. In this episode, Crowell’s Christian Curran, Zachary Schroeder, and Bryan Dewan discuss a recent Federal Circuit appeal on the Blue & Gold waiver rule, and a Court of Federal Claims protest about the “late is late” rule in the world of electronic proposal submissions.
Continue Reading All Things Protest: Blue & Gold and Late is LateFederal 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.
Continue Reading Federal Circuit Clarifies Application of Blue & Gold: Proposal Submission Deadline, Not Award, is the Operative Time for FilingAll Things Protest: Final Proposal Revisions and Federal Circuit Opinions
Crowell & Moring’s “All Things Protest” podcast keeps you up to date on major trends in bid protest litigation, key developments in high-profile cases, and best practices in state and federal procurement. In this episode, Crowell’s Christian Curran, Zachary Schroeder, and Bryan Dewan discuss a recent GAO sustain about final proposal revisions, along with two notable Federal Circuit opinions from May 2026 covering bid protest intervention and the discretion afforded to agencies in evaluating proposals.
Continue Reading All Things Protest: Final Proposal Revisions and Federal Circuit OpinionsFederal Circuit Holds Challengers to CICA Stay Overrides Need Not Satisfy Four-Factor Injunctive Relief Test
In a significant decision for government contractors, on April 15, 2026, in Life Science Logistics, LLC v. United States, the U.S. Court of Appeals for the Federal Circuit held that bid protesters challenging an agency’s override of an automatic stay of contract performance under the Competition in Contracting Act (CICA) need not satisfy the demanding four-factor test traditionally required for preliminary injunctive relief. In so doing, the Federal Circuit clarified that CICA stay override challenges need only demonstrate that the override decision was arbitrary and capricious—nothing more.
Continue Reading Federal Circuit Holds Challengers to CICA Stay Overrides Need Not Satisfy Four-Factor Injunctive Relief TestAll Things Protest: Challenging Agency Evaluations of Proposals
Crowell & Moring’s “All Things Protest” podcast keeps you up to date on major trends in bid protest litigation, key developments in high-profile cases, and best practices in state and federal procurement. In this episode, Crowell’s Christian Curran, Zachary Schroeder, and Bryan Dewan discuss challenges contractors face when protesting agency evaluations of proposals, along with…
All Things Protest: Corrective Action at the Court of Federal Claims
Crowell & Moring’s “All Things Protest” podcast keeps you up to date on major trends in bid protest litigation, key developments in high-profile cases, and best practices in state and federal procurement. In this episode, Crowell’s Christian Curran, Zachary Schroeder, and Bryan Dewan cover two recent protests at the Court of Federal Claims— Advantaged Solutions…
Fastest 5 Minutes: Cybersecurity, Resellers, IP
Crowell & Moring’s “All Things Protest” podcast keeps you up to date on major trends in bid protest litigation, key developments in high-profile cases, and best practices in state and federal procurement. In this episode, Crowell’s Christian Curran, Zachary Schroeder, and Bryan Dewan cover two recent protests that both emphasize the continued importance of filing…
The FY 2026 National Defense Authorization Act
On December 18, 2025, the Fiscal Year 2026 National Defense Authorization Act (FY 2026 NDAA) (P.L. 119-60) was signed into law. The Act makes significant changes to defense acquisition, sourcing restrictions, and interactions between the Defense Industrial Base (DIB) and the Department of Defense (DOD).
Continue Reading The FY 2026 National Defense Authorization ActAll Things Protest: NDAA, GAO’s Annual Bid Protest Report, and an OCI Sustain
In this episode, Crowell’s Christian Curran, Zachary Schroeder, and Bryan Dewan cover the latest NDAA protest provision, GAO’s Bid Protest Annual Report to Congress for Fiscal Year 2025, and GAO’s sustain of a bid protest related to an impaired objectivity organizational conflict of interest (OCI). Crowell & Moring’s “All Things Protest” podcast keeps you up…