SAMSARA INC. v. United States, 1:24-cv-00063

Following a USPS contract award to Geotab USA, Inc. for telematics devices, Samsara Inc. protested, alleging errors in proposal evaluation, particularly concerning an On-Board Diagnostic 1 (OBDI) requirement.
The Court in a prior proceeding (Samsara I) granted Samsara’s motion, finding USPS used an unstated evaluation criterion regarding OBDI and enjoined USPS from continuing with Geotab’s contract pending a corrective evaluation.
USPS conducted a limited corrective reevaluation focused solely on the OBDI criterion for Samsara’s proposal but did not reopen or amend the solicitation, nor request new proposals.
The technical and price evaluation scores remained unchanged; USPS reaffirmed the award to Geotab, prompting Samsara to file a new bid protest challenging the adequacy and scope of the corrective action.
Samsara argued the USPS did not properly take "new agency action" as required, instead relying on improper post hoc rationalizations and failing to address changed circumstances since the original award.
The Court was tasked with deciding whether USPS’s corrective action constituted new agency action and whether its approach had a rational basis under the Administrative Procedure Act (APA).

Issue	Plaintiff’s Argument	Defendant’s Argument	Held
Was the USPS’s reaffirmation new agency action?	No – USPS failed to take genuinely new action; simply revisited its prior decision.	USPS followed required procedures; reaffirmation was new agency action per precedent.	USPS’s action was new agency action.
Was there impermissible post hoc rationalization?	Yes – USPS introduced new justifications after the fact, in violation of Regents.	No – Prohibition on post hoc rationalization applies only to fuller explanations of prior action, not new agency action.	No improper post hoc rationalization.
Did the corrective action lack a rational basis?	Yes – USPS limited the review, ignored changed circumstances, and failed to amend the solicitation.	USPS had discretion to tailor corrective action; scope was proper and rationally explained.	Corrective action had rational basis.
Was procedural fairness or prejudice to Samsara shown?	Yes – Samsara lacked renewed opportunity to compete given changed facts; corrections should have been broader.	No – USPS properly complied with court order; same result permissible if rationale is new and procedurally sound.	No showing of procedural unfairness.

Banknote Corp. of Am., Inc. v. United States, 365 F.3d 1345 (rational basis and arbitrary/capricious review of procurement decisions)
Impresa Construzioni Geom. Domenico Garufi v. United States, 238 F.3d 1324 (standard for setting aside agency procurement decisions)
Dell Fed. Sys., L.P. v. United States, 906 F.3d 982 (scope of rational basis review and agency discretion in corrective action)
Emery Worldwide Airlines, Inc. v. United States, 264 F.3d 1071 (APA standards in bid protests)
Advanced Data Concepts, Inc. v. United States, 216 F.3d 1054 (highly deferential arbitrary/capricious standard for agency review)
WellPoint Mil. Care Corp. v. United States, 953 F.3d 1373 (review of agency action for rational basis in procurement)