No. 20-1057
`In the Supreme Court of the United States
`ORACLE AMERICA, INC.,
`PETITIONER,
`v.
`UNITED STATES AND AMAZON WEB SERVICES, INC.
`
`ON PETITION FOR A WRIT OF CERTIORARI
`TO THE UNITED STATES COURT OF APPEALS
`FOR THE FEDERAL CIRCUIT
`
` REPLY BRIEF FOR PETITIONER
`
`R. REEVES ANDERSON
`ARNOLD & PORTER
`KAYE SCHOLER LLP
`1144 Fifteenth Street
`Suite 3100
`Denver, CO 80202
`(303) 863-1000
`
`ALLON KEDEM
`Counsel of Record
`CRAIG A. HOLMAN
`SALLY L. PEI
`SEAN A. MIRSKI
`NATHANIEL E. CASTELLANO
`ARNOLD & PORTER
`KAYE SCHOLER LLP
`601 Massachusetts Ave., NW
`Washington, DC 20001
`(202) 942-5000
`allon.kedem@arnoldporter.com
`
`
`In the Supreme Court of the United States
`ORACLE AMERICA, INC.,
`PETITIONER,
`v.
`UNITED STATES AND AMAZON WEB SERVICES, INC.
`
`ON PETITION FOR A WRIT OF CERTIORARI
`TO THE UNITED STATES COURT OF APPEALS
`FOR THE FEDERAL CIRCUIT
`
` REPLY BRIEF FOR PETITIONER
`
`R. REEVES ANDERSON
`ARNOLD & PORTER
`KAYE SCHOLER LLP
`1144 Fifteenth Street
`Suite 3100
`Denver, CO 80202
`(303) 863-1000
`
`ALLON KEDEM
`Counsel of Record
`CRAIG A. HOLMAN
`SALLY L. PEI
`SEAN A. MIRSKI
`NATHANIEL E. CASTELLANO
`ARNOLD & PORTER
`KAYE SCHOLER LLP
`601 Massachusetts Ave., NW
`Washington, DC 20001
`(202) 942-5000
`allon.kedem@arnoldporter.com
`
`
`
`TABLE OF CONTENTS
`
`Page
`I. The Harmless-Error Ruling Warrants Review .................. 1
`A. The Rule of Prejudicial Error Does Not Trump
`Chenery ............................................................................. 2
`B. Review Is Warranted Now .............................................. 6
`II. The Conflict-of-Interest Ruling Warrants Review ................. 7
`A. This Court Should Clarify the Scope and Application
`of Mississippi Valley ....................................................... 8
`B. No Deference Is Due to Agencies in Policing Their
`Own Criminal Misconduct ............................................. 10
`Conclusion..................................................................................... 12
`
`(i)
`
`
`
`ii
`
`TABLE OF AUTHORITIES
`
`Page(s)
`
`Cases
`Bowen v. Georgetown University Hospital,
`488 U.S. 204 (1988) ............................................................ 6
`Braniff Airways, Inc. v. Civil Aeronautics Board,
`379 F.2d 453 (D.C. Cir. 1967) ........................................... 7
`Department of Commerce v. New York,
`139 S. Ct. 2551 (2019) ........................................................ 3
`Kisor v. Wilkie,
`139 S. Ct. 2400 (2019) ...................................................... 10
`Little Sisters of the Poor Saints Peter & Paul Home
`v. Pennsylvania, 140 S. Ct. 2367 (2020) ......................... 3
`Long Island Savings Bank, FSB v. United States,
`503 F.3d 1234 (Fed. Cir. 2007) ...................................... 8-9
`Massachusetts Trustees of Eastern Gas & Fuel
`Associates v. United States, 377 U.S. 235 (1964) ...... 2, 4
`National Association of Home Builders v.
`Defenders of Wildlife, 551 U.S. 644 (2007) ................. 3, 4
`Quinn v. Gulf & Western Corp.,
`644 F.2d 89 (2d Cir. 1981) ................................................ 9
`SEC v. Chenery Corp.,
`318 U.S. 80 (1943) .................................................... passim
`Spiva v. Astrue,
`628 F.3d 346 (7th Cir. 2010) ............................................. 7
`United States v. Mississippi Valley Generating Co.,
`364 U.S. 520 (1961) ............................................. 8, 9, 10, 11
`United States ex rel. Siewick v. Jamieson Science &
`Engineering, Inc., 214 F.3d 1372 (D.C. Cir. 2000) ........ 9
`
`
`
`iii
`
`Statutes
`5 U.S.C. § 706 ....................................................................... 1
`18 U.S.C. § 208 .................................................. 7, 8, 9, 10, 11
`28 U.S.C. § 1491(b)(1) .......................................................... 4
`41 U.S.C. § 1303(a)(1) ........................................................ 11
`Regulations
`48 C.F.R.
`§ 3.104-2(b)(2) .................................................................. 11
`§ 3.104-3(c)(4) .................................................................. 11
`Other Authorities
`Henry J. Friendly, Chenery Revisited,
`1969 Duke L. J. 199 .......................................................... 2
`
`
`
`In the Supreme Court of the United States
`
`ORACLE AMERICA, INC., PETITIONER,
`v.
`UNITED STATES AND AMAZON WEB SERVICES, INC.
`
`ON PETITION FOR A WRIT OF CERTIORARI
`TO THE UNITED STATES COURT OF APPEALS
`FOR THE FEDERAL CIRCUIT
`
`REPLY BRIEF FOR THE PETITIONER
`
`Unless this Court intervenes, a $10 billion government
`contract will proceed with an admittedly unlawful structure,
`secured through the criminal misconduct of agency officials.
`The government’s defense of that result—in which the Federal
`Circuit misapplied two of this Court’s decisions—inverts
`fundamental separation-of-powers principles: It urges judicial
`intervention where Congress mandated agency decision-making,
`and judicial abdication where Congress required oversight.
`The government does not dispute the importance, recurrence,
`or timeliness of the questions presented, but instead argues the
`merits. Its response confirms that the legal issues are joined,
`ripe, and cleanly presented for review.
`I. The Harmless-Error Ruling Warrants Review
`Agencies are fallible. And when they err, administrative law
`imposes dual obligations on a reviewing court: First, “[t]he
`grounds upon which an administrative order must be judged
`are those upon which the record discloses that its action was
`based.” SEC v. Chenery Corp., 318 U.S. 80, 87 (1943). Second,
`“due account [must] be taken of the rule of prejudicial error.”
`5 U.S.C. § 706. The question is whether the Federal Circuit has
`reconciled those two principles appropriately.
`
`(1)
`
`
`
`2
`
`As this case illustrates, it has not. The Federal Circuit has
`construed the harmless-error exception so broadly as to nullify
`Chenery.
`A. The Rule of Prejudicial Error Does Not Trump Chenery
`1. Courts reviewing agency errors must ask whether the
`agency’s decision-making can nevertheless be sustained in light
`of “grounds … upon which the record discloses that its action
`was based.” Chenery, 318 U.S. at 87. Properly understood, this
`inquiry fits with the prejudicial-error rule: If the agency’s
`decision “was based” on valid reasoning, then ancillary mistakes
`can be disregarded as harmless; such errors “ha[ve] no bearing
`on the procedure used or the substance of decision reached.”
`Mass. Trs. of E. Gas & Fuel Assocs. v. United States, 377 U.S.
`235, 248 (1964). But if the agency’s decision “was based” on
`invalid reasoning, then by definition the error is not harmless.
`Pet. 18-19. Even if the agency might reach the same conclusion
`through different reasoning, the agency—not a reviewing
`court—must take that step. See Henry J. Friendly, Chenery
`Revisited, 1969 Duke L.J. 199, 213 (“granted there could be
`little doubt what the SEC would do on remand [in Chenery], it
`was important to put the agency through the paces”).
`The government and the Federal Circuit conceive of the
`judiciary’s role quite differently:
`
`[The] inquiry … by its nature requires asking a hypothetical
`question: whether the outcome would have been different
`had the error not been made.
`Opp. 19. The Federal Circuit has thus transformed a record-
`based inquiry about what the agency actually said into a
`“hypothetical” inquiry into what the agency “would have” done
`“had the error not been made.” Under the Federal Circuit’s
`approach, judicial speculation is a feature, not a flaw.
`
`
`
`3
`
`Sound principles of administrative law counsel otherwise.
`Confining judicial review to what the agency actually said
`shows respect for the agency’s decision-making prerogatives.
`The government disparages this judicial modesty (at 19) as
`“[r]equiring the agency to spell out in advance what it would
`do” absent the error. That response is telling. An agency is not
`required to do anything “in advance.” If the agency opts to
`explain ex ante how it would decide alternative scenarios or
`redo a potential error, a record will exist; but if the agency
`demurs, a remand leaves the choice to the agency itself, where
`it belongs.
`2. Contrary to the government’s contention (at 19-20), this
`Court’s decisions do not support the Federal Circuit’s
`speculative approach to harmless error. The cited cases found
`remand unnecessary because the errors at
`issue were
`procedural foot-faults that “had no bearing” on the substance
`of agency decisions. Nat’l Ass’n of Home Builders v. Defenders
`of Wildlife, 551 U.S. 644, 659 (2007). Indeed, these decisions
`show how the rule of prejudicial error is properly reconciled
`with Chenery.
`In Little Sisters of the Poor Saints Peter & Paul Home v.
`Pennsylvania, 140 S. Ct. 2367, 2385 (2020), the agency failed to
`“publish a document entitled ‘notice of proposed rulemaking,’ ”
`but instead “issued an [interim final rule] that explained its
`position in fulsome detail” and invited public comment. Under
`those circumstances, this Court concluded, “any harm from the
`title of the document” did not justify remand. Ibid. In
`Department of Commerce v. New York, 139 S. Ct. 2551, 2573
`(2019), the Secretary failed to submit two separate reports, and
`instead submitted a single, consolidated report that nonetheless
`“fully informed Congress of, and explained, his decision.” And
`in Defenders of Wildlife, the EPA memorialized its decision in
`a Federal Register notice, but also included an arguably
`
`
`
`4
`
`incorrect statement that was “simply not germane to the final
`agency … decision.” 551 U.S. at 659. The Court found no need
`to remand because of that “stray statement, which could have
`had no effect on the underlying agency action being
`challenged.” Ibid.
`The agency error here is qualitatively different. The
`Department violated federal law by structuring JEDI as a
`improper” single-source procurement. App. 16a.
`“legally
`Unlike the de minimis procedural errors held harmless by this
`Court, the Department’s single-source decision is a defining
`feature of the challenged procurement that plainly bears on
`“the substance of decision reached.” Mass. Trs., 377 U.S. at
`248. The government identifies no opinion of this Court—or any
`other court outside the Federal Circuit—applying harmless error
`under comparable circumstances.
`The government nevertheless insists (at 19) that Chenery
`is inapplicable because the Federal Circuit “did not ‘uphold’ the
`single-award approach,” but merely left it in place. With
`$10 billion of taxpayer money at stake, this appeal to semantics
`is misguided: Absent this Court’s intervention, the JEDI
`contract will proceed for the next decade as an illegal single-
`source award. The government’s argument also ignores that
`bid protests serve an important public function, Pet. 23-24,
`which is why Congress authorized any “interested party” to
`raise “any alleged violation of statute or regulation in
`connection with a procurement.” 28 U.S.C. § 1491(b)(1). The
`government does not dispute that Oracle is an “interested
`party,” with standing and within the zone of interests.
`3. The government separately defends the Federal
`Circuit’s harmless-error ruling (at 15-16) on the ground that
`Oracle did not satisfy JEDI’s minimum security requirements
`“at the time of the solicitation.” This argument rests on the
`same conceptual mistake identified above—namely, that a
`
`
`
`5
`
`reviewing court should ask whether the outcome “would have
`been different” under the hypothetical record that “would
`have” existed, absent the error, at the time of the agency’s
`original decision. Opp. 19. Chenery does not permit courts to
`usurp administrative decision-making through time travel.
`When error is found, the court must remand unless the agency
`has stated its views on the existing record. In any event, a
`remand would change the outcome here even if the Department
`retained the Gate 1.2 security requirements, which Oracle now
`satisfies.
`The government’s discussion of security requirements (at
`15-19) illustrates the Federal Circuit’s flawed approach. Using
`phrases like “the agency made clear” and “[a]s the agency
`repeatedly explained,” the government
`insists that the
`Department already decided which security requirements
`would apply to a multiple-award contract. Opp. 16. One might
`expect citations to the administrative record to follow. Instead,
`the government cites statements by the Claims Court and the
`Federal Circuit. Ibid. (citing App. 3a, 22a-23a, 97a). This
`sleight-of-hand—substituting judicial conclusions for agency
`decision-making—is precisely the problem.
`The government’s few citations to the administrative
`record (C.A. App. 100,947-948, 100,955-956) say nothing about
`using multiple cloud providers, much less how the agency
`would address security in a multi-provider scenario. The many
`options on remand include: whether to use FedRAMP or a
`different protocol; whether to require certification as of
`contract performance or another time; and whether to apply
`different security requirements for multiple awards. Pet. 19-20.
`
`
`
`6
`
`Those questions were first answered not by the agency,
`but by counsel at oral argument. Pet. 10-11.* The Claims Court
`then turned counsel’s speculation into a judicial conclusion,
`App. 97a, which the Federal Circuit treated as a factual finding
`to be upheld unless “clearly erroneous,” App. 17a. Entirely
`missing from this discussion about how to structure a multiple-
`award solicitation is the one consideration Chenery requires:
`whether “the agency itself has articulated [a] position on the
`question.” Bowen v. Georgetown Univ. Hosp., 488 U.S. 204, 212
`(1988).
`B. Review Is Warranted Now
`1. The government does not dispute that the ruling below
`reflects the Federal Circuit’s consistent approach to harmless
`error. Pet. 21-22 (discussing similar cases). This case typifies
`“numerous decisions in which the CFC and the Federal Circuit
`have improperly taken over the role of agency decision makers
`in the guise of making prejudice determinations.” Claybrook
`Amicus Br. 6-7.
`
`* Selectively excerpting the transcript (at 18), the government asserts
`that “Rayel on the facts” concerned only “a ‘surge capacity’ requirement
`in Gate 1.1—not the data-security requirements in Gate 1.2.” The
`immediately following colloquy shows otherwise:
`MR. RAYEL: Because, I mean, this was a single award. So the agency
`didn’t—I’ll admit it doesn’t say in [the deputy director’s] memorandum
`[“]and my decision would be the same if there were multiple awards.[”]
`THE COURT: Right.
`MR. RAYEL: But that’s—we can look at what the requirements are,
`what the justifications are and say, is this likely a change in a multiple
`award scenario? And I think the answer is no for both 1.1 and 1.2, in
`particular. I mean, the agency needs security whether it has one or
`two or three contractors.
`C.A. App. 2296 (emphasis added).
`
`
`
`7
`
`The government also does not dispute that other Circuits
`handle harmless error differently. Pet. 18-19. Indeed, these
`courts resist the government’s frequent attempts “to dissolve
`the Chenery doctrine in an acid of harmless error.” Spiva v.
`Astrue, 628 F.3d 346, 353 (7th Cir. 2010). They understand that
`“an error cannot be dismissed as ‘harmless’ without taking into
`account the limited ability of a court to assume as a judicial
`function, even for the purpose of affirmance, the distinctive
`discretion assigned to the agency.” Braniff Airways, Inc. v.
`Civil Aeronautics Bd., 379 F.2d 453, 465-66 (D.C. Cir. 1967).
`Finally, the government does not dispute that the issue,
`which goes to the heart of agency accountability, is important
`and recurring. Pet. 23-25; Claybrook Amicus Br. 7.
`2. To discourage review, the government resuscitates a
`“tortured” argument, App. 95a, that the Federal Circuit found
`contrary to the “plain language of the statute,” App. 14a.
`Namely, the government insists (at 23-25) that a single-source
`award was lawful all along. That argument is both meritless
`and not before the Court: The government chose not to cross-
`petition its loss on that issue, which falls outside the Question
`Presented even as the government articulates it (Opp. I). Indeed,
`if the mere existence of a meritless, judicially rejected, alternative
`argument outside the QP were enough to scuttle certiorari, this
`Court’s merits docket would all but disappear.
`II. The Conflict-of-Interest Ruling Warrants Review
`Like the Federal Circuit, the government accepts that the
`JEDI procurement involved criminal conflicts of interest,
`implicating officials who “personally and substantially”
`participated despite their personal stake in its outcome.
`18 U.S.C. § 208; see C.A. App. 104,860-862 (admission). Per this
`Court’s instructions, the contract should have been set aside “to
`protect the public from the corrupting influences that might
`
`
`
`8
`
`[have] be[en] brought to bear.” United States v. Mississippi
`Valley Generating Co., 364 U.S. 520, 563 (1961).
`In response, the government argues only that Oracle—and
`even the Federal Circuit, to a degree—are wrong on the merits.
`The issue is thus squarely joined, and this Court’s review is
`needed to clarify legal principles affecting scores of government
`contracts and billions of taxpayer dollars annually.
`A. This Court Should Clarify the Scope and Application of
`Mississippi Valley
`The government disputes (at 28) that Mississippi Valley
`announced a “per se rule” requiring non-enforcement of
`contracts
`involving criminal conflicts of
`interest. The
`government’s response tees up two legal issues that are
`significant, outcome-determinative, and worthy of immediate
`review.
`1. The government (at 27) reads Mississippi Valley as
`holding only that a conflicted contract is “voidable” by the
`government, rather than “void.” Yet the Court said that when
`a contract “arises out of circumstances that would lead
`enforcement to offend the essential purpose of ” the criminal
`conflict-of-interest statute, the “contract is not to be enforced.”
`364 U.S. at 563. Indeed, the “essential purpose” of Section 208
`has always been “to guarantee the integrity of the federal
`contracting process,” which is a public good. Id. at 565. Just as
`the Judiciary may not “sanction[] the type of infected bargain
`which the statute outlaws,” id. at 563, neither may the
`Executive Branch.
`But even if Mississippi Valley left the void-versus-voidable
`question open, that only further supports certiorari. The
`government’s position conflicts with the decision below,
`App. 25a-26a, and a long line of Federal Circuit precedent. E.g.,
`Long Island Sav. Bank, FSB v. United States, 503 F.3d 1234,
`
`
`
`9
`
`1237 (Fed. Cir. 2007) (“[W]e hold that the contract is tainted
`from its inception by fraud and thus void ab initio.”); accord
`Quinn v. Gulf & W. Corp., 644 F.2d 89, 94 (2d Cir. 1981). The
`D.C. Circuit, by contrast, has accepted the government’s
`position. U.S. ex rel. Siewick v. Jamieson Sci. & Eng’g, Inc.,
`214 F.3d 1372, 1377 (D.C. Cir. 2000). Review would resolve this
`disagreement.
`2. Next, the government endorses (at 27-28) the Federal
`Circuit’s test, under which a contract is unenforceable only if a
`“causal link” can be shown between the criminal misconduct
`and the contract’s terms. But the Court in Mississippi Valley
`asked only two questions: first, whether the conduct at issue
`violated Section 208’s predecessor statute; and second, whether
`“that fact alone” rendered the contract unenforceable. 364 U.S.
`at 525. The Court answered yes to both questions. Pet. 26-27.
`In arguing that Mississippi Valley requires a causal link,
`the government relies on language from the first part of the
`opinion, where the Court decided whether a conflict even
`existed. Opp. 27-28 (citing 364 U.S. at 552, 554). But in answering
`the second question—the contract’s enforceability—the Court
`did not attempt to judge the practical impact of the conflict.
`Indeed, the Court disclaimed both the relevance and feasibility
`of such an inquiry. 364 U.S. at 565 (“It is this inherent difficulty
`in detecting corruption which requires that contracts made in
`violation of Section [208] be held unenforceable … .”).
`The government says (at 27-28) that Mississippi Valley
`“had no occasion” to decide whether proof of practical impact is
`necessary. That is incorrect. 364 U.S. at 559; see Pet. 28. But
`even if Mississippi Valley had left the question open, the Court
`should decide it now.
`3. Finally, the government doubles down (at 26) on the rule
`of prejudicial error. But harmless-error reasoning is incompatible
`with a doctrine whose “primary purpose is to guarantee the
`
`
`
`10
`
`integrity of the federal contracting process.” 364 U.S. at 565.
`Unsurprisingly, no court has accepted the government’s
`harmless-error argument in a criminal conflict-of-interest case.
`Below, both courts addressed Oracle’s conflict-of-interest
`arguments on the merits, despite finding the Department’s
`single-award choice harmless as to Oracle. App. 27a, 107a. In
`any event, the government’s harmless-error argument is
`toothless: The government admits (at 26) that at least one
`conflicted agency official participated in developing Gate 1.2,
`the very requirement under which Oracle’s bid was rejected.
`B. No Deference Is Due to Agencies in Policing Their Own
`Criminal Misconduct
`Even if a materiality inquiry were appropriate (but see
`Mississippi Valley), a court must perform it. The Federal
`Circuit should not have allowed the conflicted agency to decide
`the significance of its own misconduct, subject only to “highly
`deferential” review. App. 26a.
`1. The government concedes (at 30) that “no statute
`expressly charges administrative agencies with administering
`Section 208.” Yet the government responds (ibid.) that “it does
`not matter whether a particular statute expressly authorizes
`agencies to assess the impact of conflicts on a procurement; it
`matters only if a statute prohibits such an assessment.” That
`breathtaking assertion of administrative authority inverts
`sound principles of judicial deference: Courts defer to agencies
`if—and only if—Congress authorized them to resolve certain
`questions in the first instance. See Kisor v. Wilkie, 139 S. Ct.
`2400, 2412 (2019). Since Congress did not authorize agencies to
`administer Section 208, “it would be contrary to the purpose of
`the statute for [a] Court to bestow such a power upon those
`whom Congress has not seen fit to so authorize.” Mississippi
`Valley, 364 U.S. at 561.
`
`
`
`11
`
`The government (at 28) treats the Section 208 inquiry as if
`it were an APA adjudication, inviting agencies to erect
`“findings” and “conclusions” to shield their decision-making
`from judicial scrutiny. But the government cites nothing to
`support that analogy, and nothing does. Mississippi Valley
`emphasized the Court’s need to “mak[e] an independent
`determination as to the legal conclusions and inferences which
`should be drawn from [the record].” 364 U.S. at 526 (emphasis
`added). That “independent determination” requires judicial
`judgment, not APA-style deference.
`2. The government is also wrong (at 29) that independent
`judicial review would be “in tension with the Federal
`Acquisition Regulation.” The cited FAR section excludes
`Section 208 violations from its scope. 48 C.F.R. §§ 3.104-2(b)(2),
`3.104-3(c)(4). The statute that authorizes it, 41 U.S.C. § 1303(a)(1),
`similarly makes no mention of Section 208 or criminal law-
`enforcement duties. But if any “tension” did exist between
`Section 208 and the FAR, the statute would control.
`3. The government argues (at 31) that Oracle “could not
`prevail even under de novo review,” and provides an account of
`Deap Ubhi’s impact on the procurement (at 31-32) so divorced
`from reality that correcting its many errors would easily
`consume the word limit. But resolution of these competing
`factual narratives is an issue for remand.
`What matters here is that neither court below conducted
`an independent review. The Federal Circuit held only that “the
`contracting officer’s investigation … was sufficient,” App. 32a,
`while the Claims Court focused on “whether the [contracting
`officer’s] conclusion of no impact is reasonable.” App. 108a.
`Once this Court resolves the legal questions—who decides, and
`under what standard?—the lower courts can apply the
`appropriate standard to the record.
`
`
`
`12
`
`CONCLUSION
`The Court should grant the petition.
`
`Respectfully submitted,
`
`R. REEVES ANDERSON
`ARNOLD & PORTER
`KAYE SCHOLER LLP
`1144 Fifteenth Street
`Suite 3100
`Denver, CO 80202
`(303) 863-1000
`
`ALLON KEDEM
`Counsel of Record
`CRAIG A. HOLMAN
`SALLY L. PEI
`SEAN A. MIRSKI
`NATHANIEL E. CASTELLANO
`ARNOLD & PORTER
`KAYE SCHOLER LLP
`601 Massachusetts Ave., NW
`Washington, DC 20001
`(202) 942-5000
`allon.kedem@arnoldporter.com
`
`MAY 2021
`
`
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