A U.S. Court of Federal Claims judge has upheld the U.S. Navy’s $84.2 million contract award to CACI Inc., rejecting a challenge brought by Virginia-based Professional Analysis Inc. (PAI).
In a decision made public Tuesday, Judge David A. Tapp ruled that granting PAI’s challenge would require the court to “improperly substitute its judgment” for that of the Navy. The ruling confirms the Navy’s determination that CACI’s proposal met the solicitation requirements for the Military Sealift Command logistics support contract issued in 2023.
The Navy solicited bids for logistics, material handling, and supply chain management services, with PAI and CACI as the only offerors. CACI proposed to perform the contract for $84.2 million, while PAI offered a lower bid of $74.4 million. Following an initial award to PAI, CACI protested to the Government Accountability Office (GAO), which prompted the Navy to amend the solicitation and accept revised proposals.
Judge Tapp noted that the Navy’s final evaluation concluded CACI’s proposal offered the best value, a determination upheld by both the GAO and the court. PAI’s arguments, including claims of technical deficiencies and failure to conduct a price realism analysis, were dismissed as substantially identical to those previously addressed by the GAO.
The judge also clarified that certain certification provisions cited by PAI were not mandatory and found no evidence that CACI’s assumptions constituted exceptions to solicitation terms. He further agreed with the GAO’s conclusion that CACI’s right to seek equitable price adjustments did not undermine the firmness of its proposal.
This decision reaffirms the Navy’s procurement process and highlights judicial deference to agency judgment in complex contract disputes.
Case: Professional Analysis Inc. v. U.S., Case No. 24-1897, U.S. Court of Federal Claims
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