The dispute centered on a 10-year Strategic National Stockpile contract for the National Capitol Region. Life Science Logistics, which has operated multiple SNS sites since 2007 and holds more such contracts than any other entity, lost the contract to competitor Integrated Quality Solutions in October 2023.
LSL protested the award to the Government Accountability Office, triggering an automatic stay under the Competition in Contracting Act. The General Services Administration overrode that stay just 17 days later, determining that "urgent and compelling circumstances now exist that significantly affect the interests of the United States and do not permit waiting for the GAO decision."
LSL sued in the Court of Federal Claims, arguing the override was arbitrary and capricious. The trial court agreed and granted declaratory relief without requiring LSL to prove likelihood of success, irreparable harm, balance of equities, and public interest — the traditional four factors for preliminary injunctions.
Circuit Judge Stark, writing for the unanimous panel, affirmed. "In making this determination, we are mindful of the adverse consequences that might arise were we to decide otherwise," Stark wrote. "Were we to hold that a protestor must, even to obtain a declaration that an override is unlawful, prevail on the four-factor test, we would undesirably incentivize the government to override more (if not all) CICA stays."
The court reached the merits despite the underlying dispute becoming moot after GAO sustained LSL's protest in February 2024. The panel applied the "capable of repetition yet evading review" exception, finding that CICA disputes unfold too quickly for full appellate review within the statutory 100-day window.
The case is Life Science Logistics LLC v. United States, No. 24-1522 (Fed. Cir. 2026).