Warrior Focused Solutions, LLC v. United States

CourtUnited States Court of Federal Claims
DecidedMarch 17, 2025
Docket24-1695
StatusPublished

This text of Warrior Focused Solutions, LLC v. United States (Warrior Focused Solutions, LLC v. United States) is published on Counsel Stack Legal Research, covering United States Court of Federal Claims primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Warrior Focused Solutions, LLC v. United States, (uscfc 2025).

Opinion

In the United States Court of Federal Claims No. 24-1695 Filed: March 4, 2025 Reissued: March 17, 2025 †

WARRIOR FOCUSED SOLUTIONS, LLC,

Plaintiff,

v.

THE UNITED STATES,

Defendant,

and

VALIANT GLOBAL DEFENSE SERVICES, INC.,

Intervenor-Defendant.

W. Brad English, Emily J. Chancey, Michael R. Pillsbury, Taylor R. Holt, and Hunter M. Drake, Maynard Nexsen, PC, Huntsville, Alabama, for Plaintiff.

Daniel Bertoni, Trial Attorney, Commercial Litigation Branch, Civil Division, Douglas K. Mickle, Assistant Director, Patricia M. McCarthy, Director, and Brian M. Boynton, Principal Deputy Assistant Attorney General, U.S. DOJ, Washington, D.C.; with CPT Sana H. Daniell, Trial Attorney, U.S. Army Legal Services Attorney, for the United States.

Daniel R. Forman, Cherie J. Owen, and Roxanne N. Cassidy, Crowell & Moring LLP, Washington, D.C., for Intervenor-Defendant.

MEMORANDUM OPINION AND ORDER

TAPP, Judge.

In government contract proposals, clarity is paramount. Ambiguity frequently results in unsuccessful bids, as demonstrated in this instance. The United States Army Mission and

† This Opinion was originally issued under seal, (ECF No. 46), and the parties were directed to file a notice of redactions consistent with the Court’s instructions. That Notice was filed on March 17, 2025. (ECF No. 48). The Court accepts all proposed redactions. The sealed and public versions of this Opinion differ only to the extent of those redactions, the publication date, and this footnote. Contracting Command (“the Army”) issued the underlying procurement for training services at Fort Johnson, Louisiana. (Administrative Record (“AR__”) at 1, ECF No. 41). 1 Warrior Focused Solutions (“WFS”) filed this post-award bid protest seeking declaratory relief and requesting the Court enjoin the performance by Intervenor-Defendant Valiant Global Defense Services, Inc. (“Valiant”). (See generally Am. Compl., ECF No. 25).

The combination of a waived argument and proposal ambiguities prevents WFS from meeting its burden. WFS’s Motion for Judgment on the Administrative Record, (Pl.’s MJAR, ECF No. 27), is DENIED. The United States’ and Valiant’s Cross-Motions for Judgment on the Administrative Record, (Def.’s xMJAR, ECF No. 29; Int-Def.’s xMJAR, ECF No. 28), are GRANTED.

I. Background

Located in Louisiana, the U.S. Army’s Joint Readiness Training Center (“JRTC”) trains military forces for worldwide deployment across a range of potential theaters and conflicts. (AR1147). To fulfill this mission, the Army procures Mission Support Services (“MSS”) for Army special operation units and similar units from the Marines, Navy, and Air Force. (AR1109). In addition to eight to ten annual rotational exercises, the JRTC MSS contractor also performs scenario development, property management, technology services, after-action reviews, video support, and role-play of civilians on the battlefield. (AR1148). On January 12, 2024, the Army issued a Request for Proposals (“the Solicitation”) seeking such mission support services at the JRTC. 2 (AR1268).

A. The Acquisition 3

The Solicitation provided for the award of cost-plus-fixed-fee contract line item numbers (“CLINs”), cost reimbursement CLINs, and some firm fixed price CLINs. (AR2375–78). The Army intended award to a single contractor following a best value source selection, based on a “subjective tradeoff between cost and non cost factors.” (AR2441). The Solicitation laid out four evaluation factors: Factor 1–Mission Capability, Factor 2–Past Performance, Factor 3–Small Business Participation, and Factor 4–Cost. (AR24441–42). Mission Capability was the paramount non-cost factor, with Past Performance and Small Business Participation considered equal, but of secondary importance. (AR2441). All factors “other than cost or price, when combined, [were] approximately equal to cost or price.” (Id.).

1 The Administrative Record in this case was exchanged using the Justice Enterprise File Sharing (“JEFS”) System. A Joint Appendix with the abbreviated record was filed after briefing. (Administrative Record (“AR”), ECF No. 41). 2 Request for Proposals No. W911S821R0017 (the “Solicitation”). Further, unless otherwise indicated, the dates referenced herein occurred in 2024. 3 The Court provides some overview of these factors but will discuss them at length as they arise in the Analysis section below.

2 The evaluation of Mission Capability focused “on how well the Offeror . . . demonstrated a feasible structure and approach to ensure it has the ability to execute [Performance Work Statement (“PWS”)] requirements.” (AR2442). The Army evaluated each Offeror’s approach by creating two equally important subfactors within Mission Capability: Subfactor 1–Management Approach and Subfactor 2–Technical Approach. (AR2442–46).

Recency, relevancy, and quality were the key criteria for the Army’s Past Performance evaluation. (AR2446). Recent references were for work performed within the past three years. (AR2447). The Army planned to grade the relevancy of each reference on a sliding adjectival scale. (Id.). The Army’s quality review relied on customer input regarding the offeror’s performance on previous contracts. (Id.). The Army’s Past Performance evaluation was meant to result in a confidence rating ranging from Substantial Confidence to No Confidence. (AR2448). For Factor 3, the Army committed to evaluating the proposed level of small business participation in the acquisition’s performance. (Id.). The evaluation would compare that participation to the objectives and Minimum Quantitative Requirements established in the Solicitation. (Id.).

The collective importance of these three factors was approximately equivalent to that of Cost. (AR2441). Beyond assessing cost reasonableness, the Army intended to evaluate cost realism and adjust figures to determine the most probable performance cost. (AR2449). The Army informed offerors that the most probable cost would be used to determine the best value. (Id.).

B. Evaluation and Award

Only WFS and Valiant submitted bids. (AR Tab 24 (Valiant’s Bid); AR Tab 25 (WFS’s bid)). Valiant’s total evaluated price was $444,672,556.75, and WFS’s total evaluated price was $432,195,605.95. (AR5733). After conducting evaluations, the Source Selection Evaluation Board (“SSEB”) produced its report on July 17; its results are summarized below:

3 (AR5733–34). In its tradeoff analysis, the Army stated:

Due to their outstanding technical rating, substantial confidence past performance assessment, and having the lowest Most Probable Cost, Valiant’s proposal maximizes the Government’s ability to obtain best value. Entering discussions and allowing [WFS] to submit a revised proposal addressing identified weaknesses, significant weaknesses, and uncertainties would not change the overall end state due Valiant’s significantly higher rated proposal.

In accordance with the evaluation criteria, the proposal from Valiant Global Defense Services, Inc, is the best value to the Government and is considered fair and reasonable based on adequate price competition. The superior non- cost mission capability and past-performance factors easily support the awarding to Valiant at the approximately 3% higher proposed price.

(AR5826).

Based on its findings, the Source Selection Advisory Council recommended that the Source Selection Authority (“SSA”) award the JRTC MSS contract to Valiant. (AR5825 (“The comparative analysis of both proposals clearly indicates [Valiant] maximizes the Government’s ability to obtain best value for this critical acquisition.”)). The SSA followed that recommendation. (AR5794; AR5826).

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