Court Strikes Down PLA Requirement on Federal Construction Bid After ABC Challenge
The U.S. Court of Federal Claims ordered the removal of a project labor agreement mandate from an Army Corps of Engineers solicitation, marking another legal setback for the Biden administration’s federal construction policy.

Logo courtesy of ABC
Associated Builders and Contractors praised a decision by the U.S. Court of Federal Claims that sided with an ABC federal contractor member in a bid protest challenging the Biden administration’s project labor agreement mandate on large federal construction projects.
In an expedited ruling, Judge Ryan T. Holte ordered the U.S. Army Corps of Engineers to remove the PLA requirement from a construction solicitation valued at $35 million or more before the bidding process continues. The court found the mandate unlawful as applied to the specific project.
“ABC and its federal contractor members applaud the court for once again recognizing the real-world harm inflicted on contractors and taxpayers by unlawful and costly PLA mandates,” said Kristen Swearingen, ABC vice president of government affairs. “As in prior cases, the government failed to demonstrate any benefit to taxpayers, while the record clearly shows these mandates restrict competition and favor special interests over the vast majority of the construction workforce.”
While the decision applies only to the challenged solicitation and does not invalidate the PLA rule nationwide, ABC expects the ruling to extend to 15 additional bid protests that were consolidated and stayed pending resolution of the lead case. Those cases could soon see similar relief, removing PLA mandates from additional federal construction solicitations.
The ruling follows a Jan. 19, 2025, decision by the same court that sided with ABC members and Associated General Contractors in challenges to 12 other federal solicitations containing PLA requirements.
ABC said it will continue to support members through bid protests and litigation to ensure federal agencies comply with the law and protect competition, taxpayer value and worker choice, as the industry awaits a decision from the U.S. Court of Appeals for the 11th Circuit on whether the PLA mandate should be more broadly enjoined.
Founded in 1950, Associated Builders and Contractors is a national construction trade association representing more than 23,000 members across 67 chapters. Celebrating its 75th anniversary in 2025, ABC is committed to the merit shop philosophy and helping members build safely, ethically and profitably in communities nationwide.
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