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Do the Exclusion Archives on SAM.gov Violate Contractors' Liberty Interest?

Client Alert | less than 1 min read | 09.29.16

The suspension and debarment remedies are not meant to punish contractors for past misdeeds, yet information about past exclusions is stored indefinitely on the SAM.gov website, and this information is increasingly causing collateral consequences outside the government marketplace. In an article published in Bloomberg BNA, C&M attorneys discuss the evolution of the excluded parties list and explore how a contractor might challenge the exclusion archives as a violation of a contractor’s constitutional liberty interests.

Insights

Client Alert | 3 min read | 02.26.26

FERC Requires Refunds for Late QF Recertification

On February 19, 2026, the Federal Energy Regulatory Commission (FERC) issued Branch Street Solar Partners, LLC et al., 194 FERC ¶ 61,124 (2026) rejecting the refund reports filed in connection with the late filing of recertifications of qualifying facility (QF) status by certain affiliated companies to reflect a change in upstream ownership. FERC’s rearticulation of QF recertification timing requirements and consequences for late QF recertifications has broad and substantial implications for all QF owners. ...