On April 15, 2026, the U.S. Court of Appeals for the Federal Circuit issued its decision in Life Science Logistics, LLC v. United States, 172 F.4th 1357 (Fed. Cir. 2026). The Federal Circuit confirmed that a protester challenging an agency’s override of CICA’s automatic stay need only satisfy the APA’s arbitrary-and-capricious standard at the Court of Federal Claims, not the traditional four-factor preliminary injunction test.
The decision rejects the government’s effort to place a higher burden on protesters seeking review of stay-override determinations. It clarifies an issue that has produced inconsistent treatment at COFC and should make stay-override challenges more viable for incumbents that have filed GAO protests and faced agency overrides.
Source: Life Science Logistics, LLC v. United States, 172 F,3d 1357 (Fed. Cir. 2026). Read the decision.