United States v. Science Applications International Corp.
2013 U.S. Dist. LEXIS 178615
| D.C. Cir. | 2013Background
- U.S. sued SAIC for alleged failure to disclose organizational conflicts of interest under NRC contracts (1992 and 1999) in violation of the FCA.
- D.C. Circuit vacated FCA liability/damages verdict due to a faulty damages instruction and remanded for proceedings.
- SAIC moved to reopen discovery on damages, seeking to develop record on NRC’s continued use of SAIC work product.
- Court considered whether to reopen discovery under good cause or manifest injustice standards prior to retrial.
- Court allowed limited post-2006 discovery related to value of SAIC’s work, but denied pre-2006 value discovery and broad reopening; ordered limited discovery and scheduling dates.
- Final order grants targeted, limited discovery and sets deadlines for expert designations and a scheduling conference.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standard for reopening discovery before retrial | SAIC: apply good-cause standard | U.S.: apply manifest-injustice standard | Manifest injustice applies; good cause not required for retrial context; limited discovery allowed. |
| Whether to reopen discovery on value evidence | SAIC seeks value evidence of post-2006 NRC use | Government opposes broader value discovery | Granted in part for post-2006 value; denied for pre-2006 value. |
| Scope and limits of allowed discovery | SAIC seeks broad new record on value | Limit scope to avoid prejudice | Permits: one 30(b)(6) deposition on post-2006 value, one half-day new fact witness, post-2006 documents, supplementation of prior responses, and one additional expert per side; overall limited to value evidence. |
| Pre-2006 value evidence denied | Pre-2006 value information should be permissible | Pre-2006 discovery already concluded | Denied; focus on post-2006 value evidence only. |
Key Cases Cited
- Childers v. Slater, 197 F.R.D. 185 (D.D.C.2000) (factors for good-c cause to reopen discovery; weigh efficiency and prejudice)
- Fusco v. Gen. Motors Corp., 11 F.3d 259 (1st Cir.1993) (discovery and evidence rules; flexibility to obtain relevant information)
- Piper Aircraft Corp., 985 F.2d 1438 (10th Cir.1993) (manifest injustice balancing; limited leeway for new evidence)
- United States v. Sci. Applications Int’l Corp. (SAIC III), 626 F.3d 1257 (D.C.Cir.2010) (damages instruction error; government must prove value of delivered product; SAIC may offer contrary evidence)
- United Presbyterian Church v. Reagan, 738 F.2d 1375 (D.C.Cir.1984) (discretion in discovery rulings)
- O’Donnell, U.S. Airways, Inc. v. O’Donnell (10th Cir.2010) (final pretrial orders may be modified to prevent manifest injustice)