On June 11, 2026, the U.S. Court of Appeals for the Federal Circuit granted the federal government’s motions for a stay pending appeal in State of Oregon v. Trump (Nos. 2026-1804, 2026-1805), consolidated appeals from two decisions of the U.S. Court of International Trade (CIT) that had enjoined enforcement of tariffs imposed under Proclamation No. 11012 and Section 122 of the Trade Act of 1974. While the appeal proceeds on the merits, the government may continue to collect the Section 122 “balance-of-payments” tariffs as to the parties covered by the underlying injunctions, including the State of Washington, Burlap and Barrel, Inc., and Basic Fun, Inc., pending further order of the Federal Circuit.

On June 4, 2026, Representatives Jay Obernolte and Lori Trahan released a discussion draft of the Great American Artificial Intelligence Act (GAAIA). The proposal has generated significant attention, but many organizations may be overestimating its practical significance for their day-to-day operations. The bill is directed primarily at developers of “frontier” AI models, so for most companies using AI models in their daily operations, these requirements will not apply. Nonetheless, the bill has sparked conversation—it incorporates multiple bipartisan bills on AI, its drafters wrote an op-ed calling on the U.S. to create a national framework covering AI, and the U.S. House Democratic Commission on AI and the Innovation Economy released a statement that the draft “does not meet the enormity of the moment.”

Key Takeaways

• The bill is primarily aimed at the biggest AI developers with more than $500 million in revenue that are building cutting-edge AI models rather than most typical businesses developing in-house AI or deploying commercial AI models.
• The proposed preemption provision would leave many state-law obligations governing AI deployment intact, including employment, privacy, consumer protection, healthcare, financial services, and common-law claims.
• The draft would increase fraud-related penalties and reflects a broader enforcement trend toward applying existing fraud and misconduct frameworks to AI-enabled conduct.
• If this bill passes, many of the legal risks businesses face when using AI will remain unchanged.

Parallel proceedings in two U.S. Court of International Trade cases, Euro-Notions Florida, Inc. v. United States (No. 25-00595) and V.O.S. Selections, Inc. v. United States (No. 25-00066), are rapidly converging on what may be the central unresolved question in the IEEPA tariff refund process: must the government refund duties on entries that have liquidated and become final, even for importers who have not filed suit?

Key Takeaways

• The Office of Management and Budget (OMB) proposed sweeping revisions to the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards that, among other changes, would prohibit the use of federal funds to support DEI policies that violate federal anti-discrimination laws.
• The proposed rule introduces a broad discretionary termination provision, modeled after the FAR’s termination-for-convenience clause, that would allow agencies to terminate awards that no longer advance “agency priorities or the national interest.”
• New oversight measures include mandatory E-Verify participation, expanded conflict-of-interest disclosures, pre-issuance review criteria under which the government will evaluate applicants’ civil-rights compliance and foreign affiliations, and enhanced subaward reporting on SAM.gov.
• Comments are due 45 days after publication in the Federal Register July 13, 2026, with OMB targeting an ultimate effective date of October 1, 2026.
• Organizations receiving federal funding should continue to review DEI-related programs and policies, assess internal controls, and evaluate the impact of the expanded termination authority on current and future awards.