Science Applications International Corp. v. United States, 108 Fed. Cl. 235

Background

This is a post-award bid protest in the United States Court of Federal Claims concerning Army DLITE translation services and an IDIQ award.
SAIC alleged the Army’s evaluation ratings were arbitrary, capricious, and inconsistent with solicitation criteria, and that SAIC was prejudiced.
The Source Selection Evaluation Board (SSEB) rated SAIC as Unacceptable under Management and Marginal overall Technical, leading to disqualification from award.
The SSA affirmed the SSEB’s findings and the Army awarded IDIQ contracts to six offerors deemed to have top overall merit, creating a quality break between groups.
SAIC moved for judgment on the Administrative Record; the Army, GLS, and MEP cross-moved for judgment in their favor; the court denied SAIC’s motion and granted the defendants’ motions.
The court held that SAIC failed to prove the agency acted irrationally, violated procurement law, or that SAIC would have had a substantial chance of award but for the asserted errors.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Army’s ratings were arbitrary or irrational and not in accordance with the solicitation.	SAIC argues ratings, especially Management, were inconsistent and improperly construed.	Army contends ratings were rational, consistent with criteria, and within discretion.	No; ratings showed rational basis and deference due to national security concerns.
Whether SAIC was prejudiced by the evaluation despite documenting errors.	SAIC asserts errors deprived it of a fair opportunity and a substantial chance of award.	No substantial chance existed; the top six proposals had a clear quality break.	No actionable prejudice established; no entitlement to relief on prejudice grounds.
Whether there was unequal treatment in evaluating SAIC versus other offerors.	SAIC claims disparate treatment in technical/management ratings.	Evaluations involved substantial discretion; deficiencies were not substantively indistinguishable.	No proven unequal treatment; agency exercised discretion within bounds of evaluation criteria.
Whether injunctive relief should be granted pending appeal or reconsideration.	Granting relief would prevent irreparable harm by preserving SAIC’s opportunity to compete.	Injunctive relief would harm national security and the public interest; relief denied.	Denied; national security and public interests weighed against relief.
Whether the court should re-weigh or substitute its judgment for the agency’s technical evaluations.	SAIC urges the court to replace agency judgments with its own view.	Court defers to agency expertise in highly technical, national-security procurement matters.	Court declines to substitute its judgment; review is deferential.

Key Cases Cited

Banknote Corp. of Am., Inc. v. United States, 365 F.3d 1345 (Fed.Cir.2004) (arbitrary or capricious standard; deference to agency reasoning in bids)
IBM Corp. v. United States, 101 F.3d 746 (Fed.Cir.2011) (discretion in evaluating proposals remains highly discretionary)
E.W. Bliss Co. v. United States, 77 F.3d 445 (Fed.Cir.1996) (ratings are within agency discretion; cannot be second-guessed absent irrationality)
Motor Vehicle Mfrs. Ass’n v. State Farm, 463 U.S. 29 (1983) (agency must have rational basis and explain data-to-decision linkage)
Timken United States Corp. v. United States, 421 F.3d 1350 (Fed.Cir.2005) (agency must articulate a satisfactory explanation for action)
Bowman Transp., Inc. v. Arkansas-Best Freight Sys., 419 U.S. 281 (1974) (permissible to uphold agency action where its path is reasonably discernible)
Chenega Mgmt., LLC v. United States, 96 F.3d 556 (Fed.Cl.2010) (disparate treatment and evaluation criteria; substantively indistinguishable deficiencies)
Imperza Construzioni Geom. Domenico Garufi v. United States, 238 F.3d 1324 (Fed.Cir.2001) (procuring agency must have rational basis for its decision)