COFC Reminds Army to Sufficiently Document its Technical Evaluation to Allow Judicial Review
In a recent decision, Eleit Technology, Inc. v. United States & LogiCore Corp., No. 25-850 (January 9, 2026),the Court of Federal Claims enjoined an Army Aviation and Missile Command (“Army”) blanket purchase agreement order after finding that the Army’s technical evaluation failed to provide the level of explanation required under the Administrative Procedure Act (“APA”) to permit effective judicial review. The protester, Eleit, argued that the Army’s evaluation of Eleit’s and awardee LogiCore’s proposals fell far short of the Request for Quotation’s (“RFQ”) best-value requirements, asserting that the Army failed to document any rationale tying the content of either proposal to the adjectival ratings they received. The Court agreed.
Although the procurement was conducted under FAR Subpart 8.4’s streamlined procedures for Federal Supply Schedule orders, the Court emphasized that using those procedures does not relieve an agency of its obligation under the APA to document a rational connection between what an offeror proposed and the rating it received. Here, the technical evaluators’ worksheets largely parroted the RFQ’s definition for an “Acceptable” technical rating (which both Eliet and LogiCore received), merely stating that the proposals “meet requirements” with no strengths or weaknesses, without explaining what precisely about Eleit’s or LogiCore’s respective proposals demonstrated an “acceptable” level of technical expertise. Without that reasoning, the Court could not conduct meaningful judicial review of the Army’s technical evaluation.
The Court also concluded that the Army improperly treated the technical evaluation like a lowest price technically acceptable check rather than a qualitative best‑value comparison. Across all five evaluation worksheets, the Army’s technical evaluators simply noted that each PWS section was, “at a minimum,” adequately addressed in the offeror’s proposal. But the RFQ required the agency to do more—specifically, to determine which quotation provided the “greatest overall benefit” to the government, with technical features being more important than price. By focusing solely on minimal adequacy and failing to identify any discriminators or differences between the competing quotations, the evaluators deprived the Army’s Source Selection Authority of the information necessary to make a well-reasoned tradeoff decision. As the Court explained, best‑value decisions require agencies to differentiate between proposals, not simply confirm acceptability.
The Court further found that the Army did not document whether it applied the RFQ’s five-year recency requirement for prior experience to LogiCore’s cited experience. While offerors were not required to rely on prior experience to demonstrate expertise, the RFQ mandated that any experience used for that purpose be both recent (i.e., less than five years old) and relevant. LogiCore’s proposal cited corporate experience far older than five years, yet the Army’s evaluation record was silent as to how, if at all, the evaluators considered recency or what prior experience they relied on when assessing LogiCore’s technical proposal. Because the agency offered no explanation, the Court could not determine whether the Army had adhered to the solicitation’s recency requirement for prior experience.
For contractors, this decision underscores the importance of scrutinizing not only what an agency concluded, but how well it documented the path it took to get there. Even when an agency’s substantive judgments appear reasonable, a thin or conclusory evaluation record can also make the award vulnerable on review. Protesters should pay close attention to whether the evaluation record contains enough analysis to permit a court to understand the agency’s reasoning; if they do not, they may miss out on fruitful grounds for challenging contract awards.
The court’s opinion and order is available here.