April 13, 2026

Challenge to Energy Transfer’s Green Chile gas pipeline for OpenAI/Oracle Project Jupiter Stargate AI data center

By Tyson Slocum

read the full, three-page filing here GreenChile

On January 29, an affiliate of Energy Transfer applied for blanket authorization to build 18 miles of 24-inch diameter natural gas pipeline (which it calls Green Chile) to serve the proposed Project Jupiter data center on the New Mexico side of the northwest suburbs of El Paso, TX. Project Jupiter is a joint venture of OpenAI and Oracle as part of its broader Stargate AI plan, with initial construction performed by Borderplex Digital Assets. The sole use for the Green Chile pipeline is to supply nearly 3,000 megawatts of planned natural gas power generation to exclusively serve Project Jupiter. The power needs for Project Jupiter exceed the entire existing generation output of all of El Paso Electric’s current power capacity, with the New Mexico Environment Department revealing the facilities would annually produce hundreds to thousands of tons of several pollutants.

The Federal Energy Regulatory Commission must reject the application as incomplete, and require significant additional information into the docket in order to comply with the Natural Gas Act for two reasons. First, the application omits that the New Mexico State Land Office denied Green Chile’s right-of-way permits on March 20. Green Chile requires access to roughly a mile of state-controlled land. Because Energy Transfer has not identified whether an alternative route is possible, the application should be considered incomplete.

Second, the Commission’s active coordination with the National Energy Dominance Council to more quickly review and approve reviews of proposed projects subject to the Natural Gas Act functions as a de facto modification to the Commission’s Statement of Policy for Certification of New Interstate Natural Gas Pipeline Facilities. The Commission must include in the record of this proceeding any and all communication and agreements with the President’s National Energy Dominance Council.

On Monday, March 23, Brittany Kelm, a senior advisor with the President’s National Energy Dominance Council, informed the CERAWeek audience that it is overseeing and coordinating natural gas approvals at FERC, with the Council giving a directive to FERC and other agencies that “There will not be a federal agency or a federal regulation standing in the way to get your energy project done. Company, bring me a project, and we’re gonna get this built as quick as possible.”

Section 1 of the Natural Gas Act asserts that “the business of transporting and selling natural gas for ultimate distribution to the public is affected with a public interest.” Section 7 of the Natural Gas Act requires a certificate of public convenience and necessity be issued by the Commission prior to construction and operation of a new natural gas pipeline. The Commission’s standard of review in authorizing a certificate of public convenience and necessity under § 7 rely upon its 1999 policy statement on pipeline authorizations. Any modifications to FERC review procedures to accommodate demands by the National Energy Dominance Council have the effect of an informal modification of the Commission’s 1999 Policy Statement, and must be included as part of the record in this proceeding.

As an adjudicatory agency, the Commission has an obligation to put on the record in this proceeding any and all discussions and agreements with the National Energy Dominance Council regarding efforts by the Trump Administration to influence and dictate FERC procedures and policies regarding its review of natural gas pipeline applications. Failure to complete the record with these communications and agreements irreparably harms intervenors such as Public Citizen, who have not been invited to participate in such policy coordination. FERC’s agreements and discussions with the National Energy Dominance Council result in an unprecedented shift from FERC serving as an independent regulator to one governed by White House directives. This shift is not documented in the proceeding, and the failure to include all communications and agreements between FERC and National Energy Dominance Council harms Public Citizen’s participation in the docket.

Finally, we respond to Energy Transfer’s April 10 motion opposing our timely March 26 intervention. This proceeding involves an application for blanket authorization to build a new natural gas pipeline to supply an Artificial Intelligence data center. Not only does Public Citizen have members in New Mexico potentially impacted by the proposed pipeline, but the project will support one of the largest planned Artificial Intelligence data centers in the world. Public Citizen has been engaged at a high level on the variety of impacts that data centers have on energy markets and American communities. The proposed Green Chile gas pipeline has significant public interest ramifications for AI data center development with direct interest to Public Citizen’s mission and our members and supporters. The Commission should therefore accept Public Citizen’s intervention.

Feedback on CARB’s March 2026 Climate Disclosure Workshop

April 13, 2026

Clerks’ Office
California Air Resources Board
1001 I Street
Sacramento, California 95814

Honorable members of the California Air Resources Board (CARB),

Thank you for this opportunity to comment on the implementation of the California Climate Corporate Data Accountability Act (SB 253).[1] This letter is responsive to the Board’s requests for feedback in the March 2026 Climate Disclosure Workshop related to (a) February 2026 Board Hearing Outcomes and (b) Scope 3 Reporting Options. The undersigned organizations urge the Board to take formal action to remove the exemption for insurance companies approved on February 26, 2026 in its adoption of the California Greenhouse Gas Reporting and Climate Financial Risk Disclosure Initial Regulation, at the next Board meeting. We also encourage the Board to pursue a broad applicability approach to Scope 3 reporting (regulatory option 1), requiring all reporting entities to report on all Scope 3 categories starting in 2027. In establishing requirements for Scope 3 reporting, if the Board allows “de minimis” exemptions, it should develop clear thresholds, definitions, and decision frameworks that disallow companies from omitting certain activity emissions based on assertions that they lack “influence” over those emissions, or that those emissions are not “financially material,” which are narrower standards than SB253 requires.

February 2026 Board Hearing Outcomes: CARB should remove the exemption for insurance companies that was insufficiently justified by the Board and contrary to statute.  

As numerous public interest organizations—as well as the bill’s author and the former insurance commissioner of California—have argued previously, the Board’s decision to exempt insurance companies doing business in the state from emissions reporting requirements under SB 253 is unjustified and unlawful.[2] The decision contradicts the statute and legislative intent, exceeds the Board’s authority, and will leave a significant gap in emissions data from an industry both contributing to and exposed to significant climate-related impacts in the state. The proposed exemption was originally justified in the written proposal from CARB as a measure to promote “continuity” with the Climate-Related Financial Risk Act (SB 261). However, at the finalization hearing in February, CARB instead justified the exemption as a measure to avoid “duplicative effort” for reporting entities before finalizing the proposal that same day. This later justification is inadequate for two reasons. First, subjecting insurers to the requirements of SB 253 would not be duplicative and second, even if the requirement was duplicative, the statute does not authorize a reporting exemption. 

Subjecting insurers to the requirements of SB 253 would not be duplicative as insurance companies do not currently make standardized or comprehensive emissions disclosures to the California Department of Insurance (CDI) or any other state entity. There are significant gaps in the emissions data CDI currently collects as part of the National Association of Insurance Commissioners (NAIC) Climate Risk Disclosure Survey. Though it collects climate risk information from insurers related to insurers’ assessment and management of climate-related risks, CDI’s existing reporting requirements only encourage insurers to disclose Scope 1, Scope 2, and “if appropriate,” Scope 3 greenhouse gas emissions. There is no statute or regulation administered by CDI which requires it to collect and which requires insurers to report emissions and CDI has no authority to enforce against non-disclosure of emissions by insurers.

An analysis of the 2024 Climate Risk Disclosure Surveys submitted by the largest 20 property and casualty (P&C) insurers operating in California—covering over 70 percent of the P&C market in the state—reveals CDI does not have emissions data from insurers that would satisfy the requirements of SB 253.[3] Of these 20 insurers, 15 reported their Scope 1 & 2 emissions to CDI. Ten of these insurers reported some—in many cases negligible—Scope 3 emissions. Only two of these insurers reported Scope 3 emissions inclusive of emissions from their investment portfolios, and none reported Scope 3 emissions inclusive of their underwriting portfolios. Five did not disclose any emissions in their reporting to CDI or did not submit a Climate Risk Disclosure Survey response at all. 

Currently, CDI has very little insight into the emissions contributions of the insurance companies they supervise. Only 10 percent of the largest P&C insurers in California are reporting meaningful Scope 3 emissions. Given that Scope 3 emissions, including emissions from insurer underwriting and investment, comprise over 95 percent of insurer emissions, insurer emissions reporting without comprehensive Scope 3 disclosure is largely meaningless.[4] The disclosure currently provided to CDI is not duplicative of the emissions disclosure insurers are required to provide under SB 253. 

Furthermore, even if the emissions disclosures insurers made to CDI were comprehensive, these disclosures would not justify exempting insurers from submitting emissions disclosure to CARB. SB 253 does not authorize CARB to exempt insurers or any other sector from disclosing to CARB. Instead, the statute permits a reporting entity already reporting emissions to another national or international entity to submit those emissions disclosures to CARB as well, so long as those disclosures meet the requirements of SB 253. If insurer responses to the NAIC Climate Risk Disclosure survey administered by CDI included emissions disclosures for Scope 1, 2 and 3 and otherwise met the requirements of SB 253, then it would be permitted for insurers to submit those disclosures to CARB. The statute does not, however, authorize CARB to exempt insurers from disclosing emissions to CARB. 

In addition, CARB did not provide an opportunity for public comment on the justification that the requirements under SB 253 would be “duplicative” for insurers before finalizing the exemption. For this reason, and for the legal and factual shortcomings of the justification, CARB should propose removing the exemption from the regulation at its next Board meeting. 

March 2026 Workshop Proposal: CARB should choose regulatory option 1 (broad applicability) for Scope 3 reporting. If CARB maintains allowance for “de minimis” exemptions, it must establish clear thresholds, definitions, and decision frameworks to produce complete and consistent full-scope greenhouse gas inventories in line with the explicit text of SB253 and “in conformance with the Greenhouse Gas Protocol standards and guidance.” [5]

At the March 2026 Climate Disclosure Workshop, CARB proposed granting companies “the flexibility to not report categories they consider ‘de minimis’ as long as they provide appropriate explanation.”[6] To enable that outcome, CARB described three potential factors that companies could use to make a “de minimis” determination for a Scope 3 category: 1) “volume of emissions associated with the category,” 2) the “influence an entity has over those emissions,” and 3) whether the category is considered “typically material” for the sector.[7]

If CARB allows for “de minimis” exemptions, “volume of emissions associated with the category” is the only factor CARB should permit companies to use when justifying a “de minimis” determination, or at least it should be a necessary prerequisite to such a determination. Allowing the second proposed factor (“influence over emissions”) to justify “de minimis” determinations and omissions would be inconsistent with the plain text of the law, and the third proposed factor, as described, (“typical materiality” for the sector) would need to be further constrained and redefined to conform with the law. 

SB253 specifically defines Scope 3 emissions as those “from sources that the reporting entity does not own or directly control [emphasis added] and may include…use of sold products.”[8] SB253 also recognizes that emissions that occur anywhere in a company’s value chain are important to California stakeholders, finding that companies “increase the state’s climate risk through emissions activities that include, but are not limited to, company operations, supply chain activities, employee and consumer transportation, goods production and movement, construction, land use, and natural resources extraction.”[9]

High emissions companies and sectors have long argued that value chain emissions—in whole or in part—are out of their “control” or “influence.” For example, the American Petroleum Institute (API) wrote to the Securities and Exchange Commission in 2022 that “GHG emissions from other companies’ operations are not within the control of the issuer,” in the course of arguing the SEC should “not require Scope 3 reporting.”[10] If a new or expanded carbon tax is enacted at the gas pump, it would obviously impact a gasoline supplier financially even if the emissions actually are emitted by their customers—or their customers’ customers—just as new methane leakage rules for pipelines would financially impact a natural gas power plant buying fuel from a regulated supplier. Further, if a company’s ability to influence certain emissions within their value chain is more limited, those emissions may represent the hardest-to-mitigate risk and be the most relevant to users of the data if they exist in significant volumes. Whether or not an issuer feels they have “control” or “influence” over emissions within their supply chain, they can still represent a risk to the firm. SB253 plainly states these value chain emissions “increase the state’s [emphasis added] climate risk”[11] and considers them proper targets for this reporting regime.

Additionally, the GHG Protocol is unequivocal: “While a company has control over its direct emissions, it has influence over its indirect emissions. A complete GHG inventory therefore includes scope 1, scope 2, and scope 3.”[12] The only example provided by GHG Protocol for a Scope 3 activity omission based in part on “influence” is when the company finds that “based on initial estimates, some scope 3 activities are expected to be insignificant in size (compared to the company’s other sources of emissions) and that for these activities, the ability to collect data and influence GHG reductions is limited. In such cases, companies may exclude scope 3 activities from the report, provided that any exclusion is disclosed and justified.”[13] In other words, GHG Protocol is not saying that a lack of “influence” over a Scope 3 category or activity alone justifies omission, but rather that the level of “influence” can be considered if the volume of emissions from the activity is “insignificant” in the company’s overall inventory. This is reinforced in Section 7.1 which establishes that Scope 3 activity prioritization for data collection efforts should be based on volume first (emissions, spend, or revenue-based), and allows, “[i]n addition,” for other activities to be prioritized based in part on “influence.”[14] To avoid creating a loophole that allows companies to omit emissions activities based on a self-asserted lack of “influence” over them, CARB should entirely delete the “influence” factor from the “de minimis” framework.

GHG Protocol goes on: “In particular, companies should not exclude any activity that is expected to contribute significantly to the company’s total scope 3 emissions.”[15] For full-scope greenhouse gas inventories to be not misleading for users, they must be meaningfully complete, and that requires a very high proportion of Scope 3 emissions to be accounted for and reported. Given too much discretion and flexibility, different companies might use different thresholds when determining volumes of emissions that are “de minimis.” Here again, API’s comments to the SEC are instructive of the industry’s thinking: “determination of whether Scope 3 emissions are material…based upon the relation of Scope 3 emissions to a registrant’s overall GHG footprint takes away from individual issuers that are much better positioned to make such a decision.”[16] In essence, API argues against using thresholds based on volume relative to the overall emissions inventory, and instead supports allowing companies to make their own judgments even for large-volume categories of emissions.

Users might draw inaccurate conclusions from greenhouse gas inventories when comparing firms with relatively high Scope 1 and 2 emissions, compared to those with relatively high Scope 3 emissions, if Scope 3 emissions inventories are not meaningfully complete. To avoid misleading users and undermining the usability and reliability of the entire database, CARB should set clear quantitative thresholds that allow a category of Scope 3 emissions to be considered “de minimis,” for example, if the Scope 3 activity or category represents less than 0.5 percent of the overall volume of the Scope 3 inventory.

With respect to the third proposed “de minimis” factor (“typical materiality” for the sector), if CARB does not omit it entirely, it should set a definition of materiality that aligns with text and intent of SB253, and allow it to be factored in only in cases where the emissions category or activity already falls under the volumetric “de minimis” threshold.

SB253 requires Scope 3 reporting “in conformance with the GHG Protocol standards and guidance,”[17] which states: “GHG accounting and reporting of a scope 3 inventory shall be based on the following principles: relevance, completeness, consistency, transparency, and accuracy,” where “relevance” requires that reporting entities “[e]nsure the GHG inventory appropriately reflects the GHG emissions of the company and serves the decision-making needs of users – both internal and external to the company.”[18] In determining “relevance” or “materiality” in this context, SB253 identifies the “users” of this data as “California investors, consumers, and other stakeholders” who “deserve transparency from companies regarding their greenhouse gas (GHG) emissions to inform their decisionmaking,” and who “have a right to know about the sources of carbon pollution, as measured by comprehensive GHG emissions data of those companies benefiting from doing business in the state.”[19]

Under SB253, emissions categories are “relevant” not only if they are “financially material,” but if they help inform the decisionmaking of California investors, consumers, and stakeholders, so any “de minimis” omissions based in part on a lack of “relevance” would need to be justified on the grounds that California investors, consumers, and other stakeholders would find the category lacks “relevance” in their decisionmaking. CARB should clarify that any “de minimis” omission of a Scope 3 category or activity—based in part on a purported lack of “relevance”—must include a compelling justification grounded explicitly in the statutory text of SB253, characterized by a lack of relevance from the perspective of California stakeholders broadly, not based narrowly on the perspective of the reporting entity or its shareholders.

Finally, it is critical that finance sector companies report the full range emissions from their financial activities, which include emissions from investments, capital markets activities, and insurance underwriting. The Partnership for Carbon Account Financials (PCAF) is a widely used international accounting standard that satisfies GHG Protocol’s Scope 3-Category 15 requirements.[20] CARB should clarify that reporting entities should use the PCAF standards to satisfy their Scope 3-Category 15 requirement under SB253.

We appreciate this opportunity to comment and urge CARB to remove the exemption for insurance companies and propose a Scope 3 emissions standard that will deliver complete, transparent, and useful corporate emissions data for California investors, consumers, and other stakeholders. Please reach out to Alex Martin (alex@ourfinancialsecurity.org) and Elyse Schupak (eschupak@citizen.org) if you have any questions.

Sincerely,

Americans for Financial Reform Education Fund
Consumer Watchdog
Dave Jones, CA Insurance Commissioner, Emeritus
Public Citizen
Sierra Club California

[1] California Senate Bill (SB) 253. Wiener, Stats. 2023, ch. 382; codified in Health and Safety Code Section 38532, as amended.
[2] Public Citizen et al. Comment on CARB’s Proposal to Exempt Insurance Companies from Carbon Disclosure. February 9, 2026; Camille von Kaenel. “California advances emissions disclosure rules for large companies.” E&E News. February 27, 2026.
[3] Elyse Schupak. Public Citizen. “Contrary to their claims, California regulators have little insight into insurer emissions.” March 25, 2026.
[4] KPMG International. “ESG in insurance: Insured emissions.” 2023.
[5] California Senate Bill (SB) 253. Wiener, Stats. 2023, ch. 382; codified in Health and Safety Code Section 38532, as amended, at Section 2(c)(2)(A)(ii).
[6] CARB. “Audiovisual recording of SB 253 Public Workshop: California Corporate Greenhouse Gas Reporting Program.” Remarks at 27:34. March 23, 2026.
[7] Ibid. at 27:55.
[8] California Senate Bill (SB) 253. Wiener, Stats. 2023, ch. 382; codified in Health and Safety Code Section 38532, as amended, at Section 2(b)(5).
[9] Ibid. at Section 1(g).
[10] American Petroleum Institute. “Comment to the Securities and Exchange Commission on the Proposed Rule ‘The Enhancement and Standardization of Climate-Related Disclosures for Investors’.” At page 14. June 17, 2022.
[11] California Senate Bill (SB) 253. Wiener, Stats. 2023, ch. 382; codified in Health and Safety Code Section 38532, as amended, at Section 1(g).
[12] Greenhouse Gas Protocol. World Resources Institute and WBCSD. “Corporate Value Chain (Scope 3) Accounting and Reporting Standard.” At page 27. 2011.
[13] Ibid. at page 27.
[14] Ibid. at page 66.
[15] Ibid. at page 60.
[16] American Petroleum Institute. “Comment to the Securities and Exchange Commission on the Proposed Rule ‘The Enhancement and Standardization of Climate-Related Disclosures for Investors’.” At page 14. June 17, 2022.
[17] California Senate Bill (SB) 253. Wiener, Stats. 2023, ch. 382; codified in Health and Safety Code Section 38532, as amended, at Section 2(c)(2)(A)(ii).
[18] Greenhouse Gas Protocol. World Resources Institute and WBCSD. “Corporate Value Chain (Scope 3) Accounting and Reporting Standard.” At page 23. 2011.
[19] California Senate Bill (SB) 253. Wiener, Stats. 2023, ch. 382; codified in Health and Safety Code Section 38532, as amended, at Section 1.
[20] Partnership for Carbon Accounting Financials website. 2026.

Billion Dollar Collapse: The Anatomy and Failure of an ICE Detention Center Contract

By Douglas S. Pasternak

As part of its mass detention and deportation project, the Trump administration is funding the construction and operation of detention centers around the country.

The surge in funding has created opportunities for corruption and profiteering by corporations with insider ties. The administration is awarding large contracts to businesses with little prior experience, as well as to more well-established corporations with dubious records, setting off alarm bells about the quality of construction and the treatment of detainees.

One major detention facility located on the grounds of Ft. Bliss in El Paso, Texas is known as Camp East Montana.[1] The 5,000-person facility is being built in the same location that housed Japanese-Americans in internment camps during World War II, and its construction has been condemned by Japanese-American and other groups.[2]

The administration first awarded a $1.3 billion contract to construct and operate the detention center to a company with no prior experience constructing or operating a detention facility, Acquisition Logistics LLC.[3] The contract has a financial ceiling of $2.7 billion.[4] Eight months after the contract was first awarded in July 2025, due to a litany of lethal and other problems, the Department of Homeland Security (DHS) replaced Acquisition Logistics with Amentum Services, Inc. Amentum Services, which has its own troubled history, received a no-bid, sole-sourced contract of an undetermined amount last month.[5]

Public Citizen’s investigation shows that DHS is replacing one troubled contractor with another company that has a history of engaging in multiple regulatory violations, particularly health and safety violations, which may endanger the thousands of detainees housed at Camp East Montana. In addition, some of the subcontractors tied to the Immigration and Customs Enforcement (ICE) facility at Ft. Bliss have been political donors to Republican campaigns and have close ties to the Trump family, raising questions about how some of these companies were selected in the first place. Deaths and disease infected Camp East Montana under the management of the previous contractor. It is unclear whether conditions at the facility will improve with the new contractor given its past challenges abiding by regulatory health and safety requirements.

Among Public Citizen’s key findings:

• The new DHS contractor, Amentum, has been a defendant in 40 lawsuits in federal court over the past eight years, involving false claims act, antitrust, wage and hour, and human trafficking allegations;[6]
• Over the past two decades, Amentum Holdings, Inc., the parent company of Amentum Services, Inc., and its other affiliated companies have been involved in at least 112 separate violations of U.S. regulations, including workplace safety and health violations, false claims act violations, wage and hour violations, and employment discrimination, nuclear safety, family and medical leave, labor relations, and environmental violations.[7]
• The company’s predecessor in running the same El Paso detention center, Acquisition Logistics, was never registered to operate in Texas, during the term of its contract in violation of Texas state law;[8]
• The U.S. Army, which transferred the Acquisition Logistics contract to DHS in November 2025 was found by a federal judge to have violated federal contracting regulations and the Competition in Contracting Act (CICA),[9] by not temporarily suspending the contract in July 2025, when a bid protest was filed with the Government Accountability Office (GAO) by Gemini Tech Service LLC;[10]
• Acquisition Logistics was a respondent in seven lawsuits filed by detainees at the facility between September 2025 and February 2026;[11]
• One Acquisition Logistics subcontract worker, named Hector Gonzalez, died on site at Camp East Montana in an industrial truck related accident on July 21, 2025, two days after the Acquisition Logistics contract commenced;[12]
• At least three detainees also died at the Camp East Montana facility between December 2025 and January 2026;[13]
• One of those deaths was reportedly ruled a homicide by the El Paso County Medical Examiner’s office, and witnesses reported the individual had a physical confrontation with guards just prior to his death;[14]
• From 2021 to 2024, an Acquisition Logistics subcontractor at Camp East Montana, Disaster Management Group (DMG), was fined a total of $17.7 million, in six separate cases by the Department of Labor for wage and hour violations;[15]
• The worker who died at the facility in July 2025 was reported to have worked for DMG.[16] However, that worker may have actually worked for another company named Base International, Inc.[17] Both companies are owned by Nathan (“Nate”) Albers a close associate of the Trump family.[18] In early March 2026, Albers’s wife, Kimberly Albers, co-chaired a pet fundraiser at Mar-a-Lago along with Lara Trump;[19]
• In 2019, a separate Albers company, TentLogix was charged by the Department of Justice (DOJ) “with conspiring to conceal and harbor” 92 aliens for the purpose of commercial advantage by recruiting and employing individuals they knew had entered the country illegally.[20] Albers was not charged in the case, and has since left the company, but several of his TentLogix business partners served time in prison as a result of these unlawful actions and the company was placed on four years’ probation as part of a corporate compliance agreement with the Department of Justice.[21]

CAMP EAST MONTANA – CONTRACT

On June 9, 2025, the U.S. Army issued a solicitation notice for a contractor to build and operate a large immigration detention center in the Chihuahuan Desert at Fort Bliss in Texas.[22] The Army received 11 offers on the contract, and on July 18, 2025, the Army issued a firm-fixed-price contract award to Acquisition Logistics LLC to construct a 5,000-bed ICE detention facility at Ft. Bliss in El Paso, Texas, called Camp East Montana.[23] The contract has been widely reported as a $1.3 billion contract. However, that appears to be for a single task order of the contract.[24] USAspending.gov shows that the full indefinite delivery / indefinite quantity (IDIQ) contract has an actual ceiling price of $2.7 billion.[25]

The contract award raised immediate concerns. Acquisition Logistics, LLC, established in Virginia in 2008,[26] for instance, does not appear to have a main office and is registered to a home in Richmond, Virginia that is owned by Kenneth Alan Wagner, a retired Navy Commander, and the founder and owner of the company, according to Virginia Secretary of State records.[27] In addition, the company only has between 8 and 50 employees, according to ZoomInfo[28] and RocketReach,[29] making their successful management of a billion-dollar contract appear cumbersome at best given their size.

Acquisition Logistics LLC has a very limited public footprint. One available brochure says they focus on five key areas, program management, logistics and supply chain, acquisition support, engineering support, and technology integration.[30] They have had around 30 previous federal contracts with various agencies, including the U.S. Army, U.S. Navy, U.S. Marine Corps, Defense Logistics Agency, Federal Aviation Administration, and Department of the Interior. Their cumulative total federal contracts since 2008, excluding the recent billion-dollar contract, have been around $48 million, and the largest single contract was valued at $16 million.[31]

CONTRACT AWARD

 The U.S. Army’s contract to Acquisition Logistics was “to construct, operate, and maintain a new 5,000-capacity short-term detention facility at Fort Bliss, Texas … for single adults awaiting immigration proceedings or removal from the United States.”[32] This facility was named Camp East Montana, after the name of the road where it is situated, and the site began receiving detainees in August 2025. In November 2025, the contract was transferred from the Department of Defense to the Department of Homeland Security.[33]

During World War II Fort Bliss held Japanese-Americans and Italian and German prisoners of war.[34] Photos of the facility during World War II[35] in the 1940s and today are included below.[36]

CONTRACT BID PROTEST

 On July 28, 2025, ten days after the U.S. Army awarded the ICE detention contract to Acquisition Logistics, LLC, Gemini Tech Service LLC, based in Willow Park, Texas, filed a bid protest with the Government Accountability Office (GAO).[37] The Competition in Contracting Act (CICA), calls for a temporary “stay of contract performance” once a bid protest is lodged with the GAO. In this case, however, the U.S. Army determined that it would override the stay and on July 28, 2025, directed Acquisition Logistics to continue with the task order under the contract in violation of what is known as a “CICA stay.”[38] The U.S. Army also failed to notify GAO of its action until three days later, on July 31, 2025. On August 1, 2025, the Army issued a 10-page determination and findings (“D&F”) report regarding the contract and filed that with the GAO on August 4, 2025.[39]

On August 11, 2025, due to the Army’s actions, Gemini filed a lawsuit regarding the contract award with the United States Court of Federal Claims.[40] Gemini made three key allegations in their lawsuit: 1) that Acquisition Logistics failed to comply with two material solicitation requirements, proposing a final site design and failing to propose critical utilities; 2) the Army failed to evaluate the quality of offerors’ past performance; and 3) the Army’s “responsibility determination” was unreasonable.[41]

According to the court’s 18-page “Opinion and Order,” filed under seal on September 8, 2025, and publicly released on September 18, 2025:

“Although the Army corrected its error, the Court notes that by proceeding with the contract performance without first notifying GAO and executing a written determination, the Army violated the statute by failing to comply with the CICA stay which was in place.”[42]

The Army laid out its justification for violating the CICA in its D&F report. The Army argued that it had determined that there were “urgent and compelling circumstances which significantly affect interests of the United States [that] will not permit waiting for the decision of the GAO’s decision in the protest.”[43] The Army also noted that the contract aligned with priorities in President Trump’s Executive Order 14159, which directs for the efficient and expedited removal of aliens from the United States.[44]

In its D&F, the Army wrote:

“[A] continued stay will directly exacerbate the existing detention capacity crisis, hindering ICE’s ability to effectively manage the influx of detainee apprehensions. This will result in increased operational risks, potential legal challenges related to overcrowding, and a heightened strain on resources. The delay will also disrupt planned operational deployments and enforcement activities reliant on adequate detention capacity, directly impacting ICE’s core mission as outlined in the SOO [Statement of Objectives]. The current overcapacity situation is unsustainable and demands immediate action to ensure humane treatment, appropriate care, and legal compliance.”[45]

The U.S. Army’s D&F also argued:

“The Department of Homeland Security (OHS) reports 1.5 million active final removal orders, yet only 41,500 federally funded bed spaces are currently available, necessitating reliance on state- funded facilities to address the shortfall. Current detention facilities are critically overcrowded, housing 57,600 individuals. This overcrowding creates unsafe conditions for both U.S. Immigration and Customs Enforcement (ICE) agents and those in custody, increasing the risk of altercations, health crises, and potential security breaches. Failure to address this capacity gap poses significant operational, security, and humanitarian risks, demanding immediate attention and resolution. Therefore, the benefits of overriding the stay and proceeding with performance greatly outweigh the potential costs of not doing so.”[46] [Emphasis added].

In addition, the Army claimed, based on projections from Acquisition Logistics LLC, that temporarily halting the contract and construction work would add more than $500 million in additional costs.[47] It seems clear that the Army was arguing that these economic costs and their security concerns with temporarily suspending the Acquisition Logistics contract outweighed the requirements of abiding by the law and the Competition in Contracting Act, which required them to temporarily halt the contract once Gemini filed its bid protest with GAO.

The Army’s D&F argued, “Given the substantial progress already achieved by the current awardee and the nature of the work completed to date, transitioning performance to a new vendor would present significant logistical and operational challenges. Replicating the established infrastructure, personnel, and ongoing operational tempo would introduce unacceptable risk to mission continuity and potentially result in substantial delays and increased costs.”[48]

In the end, the court said it “was disappointed with the Army’s actions in this procurement,” but because it found there was a “reasonable basis for the Army’s decision” the court denied the plaintiff’s motion for a preliminary injunction and dismissed the complaint.[49]

The contract was transferred from the Department of Defense to the Department of Homeland Security in November 2025.[50] Ironically, DHS terminated the contract with Acquisition Logistics in mid-March 2026 due to a litany of problems and replaced it with a new contractor, Amentum, who had been a subcontractor under Acquisition Logistics on the project.[51]

The DHS contract Acquisition Logistics received was the first time they had obtained a DHS contract, and it was more than 81 times larger than any other contract they had ever managed. The largest previous contract they had won was widely reported to have been a $16 million federal contract.[52] The $1.3 billion DHS contract was more than 8,000% larger than their $16 million contract and it was 27 times larger than all other contracts the company had ever won combined.

TEXAS BUSINESS REGISTRATION

Although Acquisition Logistics LLC began operating in Texas in July 2025 to initiate the construction of Camp East Montana, the company failed to register with the Texas Secretary of State’s office in violation of Texas law. The company only attempted to register with the Texas Secretary of State’s office on March 19, 2026, after DHS had terminated their contract. However, according to an official with the Texas Secretary of State’s office the company’s registration was rejected on March 21, 2026, because they had improperly filed out the necessary registration form.[53]

Acquisition Logistics operated illegally in Texas for eight months. The Texas Secretary of State’s office says that failure to register for out-of-state entities may result in penalties, including:

• Inability to maintain an action, suit, or proceeding in a Texas court until registration;
• Injunction from transacting business in Texas;
• Civil penalty equal to all fees and taxes that would have been imposed if the entity had registered when first required; and
• Late filing fees owed to the secretary of state by an entity registering more than 90 days after first transacting business in Texas.[54]

ACQUISITION LOGISTICS – SECRECY

Secrecy has plagued both Acquisition Logistics LLC and its DHS contract. There has been no public release of any of Acquisition Logistics subcontractors, for instance, and the company’s own website (https://acq-log.com/) is hidden behind a virtual digital wall, where a password and logon is needed to access the site.

DISASTER MANAGEMENT GROUP (DMG) LLC

The company’s subcontracts have also been cloaked in secrecy. However, in July 2025, ProPublica reported that Disaster Management Group (DMG), LLC, owned by Nathan Albers, was one of Acquisition Logistics LLC’s subcontractors.[55] In January 2024, DMG signed a compliance agreement with the Department of Labor regarding worker wage violations at McGuire Air Force Base in New Jersey. The Department of Labor’s press release said:

“A widespread investigation by the U.S. Department of Labor has recovered nearly $16 million in back wages and restored over 24,700 paid sick leave hours to leave banks for more than 2,800 workers denied their full wages and benefits by 62 subcontractors hired to construct temporary housing and provide services to Afghan refuses at Joint Base McGuire-Dix-Lakehurst in New Jersey.

After 75 investigations that included Jupiter, Florida-based Disaster Management Group LLC, one of the project’s general contractors, and 61 subcontractors, the department’s Wage and Hour Division found DMG and its subcontractors violated [multiple] federal law[s].”[56]

In total, DMG was fined six times by the Department of Labor for wage and hour violations between 2021 and 2024, amounting to an additional $1.7 million in penalties.[57]

In 2006, Albers and Gary Hendry established Disaster Management Group, LLC together in Florida.[58] According to Florida Secretary of State records they remained co-owners and partners at DMG through 2019. Hendry appears to have left the company in 2020.

At the same time Hendry was running DMG with Albers, however, he was also running another industrial tent company called Premier Party Rentals, Inc. as the Chief Executive Officer (CEO) that he established in 1996 in Florida. In 2007, the year after Albers and Hendry established DMG, Albers also joined Premier Party Rentals, Inc.[59] On July 30, 2010, they changed the name to TentLogix, Inc.[60]

In July 2019, Hendry and two other TentLogix executives were charged “with conspiring to conceal and harbor aliens for the purpose of commercial advantage by recruiting and employing individuals they knew had entered the country illegally.[61] Hendry was also charged with making false statements. In December 2019, Hendry was sentenced to one year and one day in prison and ordered to forfeit $282,789 to the U.S. government and pay a $75,000 fine.[62] TentLogix was sentenced to four years’ probation and signed a corporate compliance agreement for employing 92 aliens that had entered the country illegally.[63] The company declared bankruptcy in November 2020 in U.S. Bankruptcy Court in the Southern District of Florida.[64] For his part, Albers was never charged with any crime and appears to have severed ties with TentLogix in 2019.

A FATAL ACCIDENT

The contract for Camp East Montana was troubled from the very start. Saturday, July 19, 2025, was the start date of the U.S. Army issued contract.[65] On Monday, July 21, 2025, just two days after the contract was underway there was a fatal accident at the Camp East Montana site involving Acquisition Logistics LLC,[66] JMJ Production Services,[67] Fulfillment Personnel Services,[68] and Base International Inc.,[69] a company established by Nathan Albers in Delaware in December 2023, that is also registered to operate in Florida.[70] The media has reported that the individual who died was a 38-year-old man named Hector Gonzalez, who was reportedly working for Albers’ other company, Disaster Management Group (DMG).[71] However, a search of Occupational Safety and Health Administration (OSHA) records does not identify any record for DMG, but it does identify Base International Inc. as being involved in the July 21^st accident.[72] An obituary posting on Legacy.com has a video montage celebrating a Hector Horacio Gonzalez, who was 38 years old and died on July 21, 2025, which matches the age of the Hector Gonzalez that died at Camp East Montana.[73] The video montage suggests that he had three daughters. However, there is no information about how he died or where he worked. As of April 6,  2026, the obituary says it is being updated.

The specifics of the accident are still unclear. However, Base International, JMJ Production Services, and Fulfillment Personnel Services were all cited by OSHA for not meeting industrial truck design, inspection, testing, maintenance, and operation standards. JMJ Production Services[74] and Fulfillment Personnel Services[75] were also cited for not certifying that each operator had been properly trained and evaluated. Both companies were cited for two separate “serious” OSHA violations, agreed to an informal settlement on February 18, 2026, and each company paid a reduced penalty of $15,000. Base International, Inc. was cited for violating the truck standards issue mentioned above, described by OSHA as a “serious” violation, but the company contested its $11,585 fine on February 13, 2026. The final OSHA fine regarding Base International appears to remain unresolved. The OSHA records do not show that Acquisition Logistics was cited for any specific violation or fined, but they do link Acquisition Logistics to the July 21, 2025, accident and OSHA records show that OSHA closed the case regarding Acquisition Logistics on January 21, 2026.[76]

DEATH OF DETAINEES

Besides the death of a worker at the site, multiple reports have shown that the health and safety of those detained at the Camp East Montana facility are in jeopardy. In September 2025, the Washington Post reported that an internal ICE report found the facility had 60 violations of ICE detention standards in just 50 days.[77] In early March 2026, the Associated Press reported that they had reviewed 130 emergency 911 calls from Camp East Montana between mid-August 2025 through January 20, 2026, that revealed at least six attempted suicide attempts, at least 20 seizures, some reportedly due to head trauma, and other medical traumas and mental health related emergencies.[78]

In addition, over a seven-week span from December 3, 2025, to January 15, 2026, three detainees died at the facility. Francisco Gaspar Andrés, age 48, from Guatemala died on December 3, 2025, after being hospitalized for two weeks at a local El Paso hospital. The initial cause of death was reported as “natural liver and kidney failure.”[79] Exactly one month later on January 3, 2026, Geraldo Lunas Campos, 55, from Cuba, died after a confrontation with Camp East Montana guards.[80] The El Paso County Medical Examiner’s office reportedly declared the death to be a homicide caused by asphyxia due to neck and torso injuries while being physically restrained, although ICE officials initially claimed he died after an attempted suicide.[81] Two weeks later, on January 15, 2026, a 36-year-old Nicaraguan man, Victor Manual Díaz, died from an apparent suicide.[82] He was found unconscious in his room by security staff and pronounced dead at the time he was discovered.

AMENTUM – BACKGROUND & CONTRACT JUSTIFICATION

Whether or not the new contractor, Amentum, that has been hired for just 180 days (six months) to take over the Acquisition Logistics contract will perform much better is unknown. Amentum is a much larger company. It has more than 50,000 employees in more than 70 countries and generated more than $14 billion in revenue in 2025 alone.[83]

Amentum was formed in 2020 as a spinoff of AECOM’s Management Services Group. In March 2024 they merged with Jacobs’ Critical Mission Solutions and Cyber and Intelligence business, and in September 2024 Amentum Government Services Holding became Amentum Holdings, Inc. merging Amentum Services, Inc. with Jacobs Solutions.[84]

On March 11, 2026, DHS issued a “notice of intent to award a sole source-contract” to Amentum Services, Inc. for “detention and facility management services at Camp East Montana.”[85] The new contract says, “Amentum Services Inc. will provide comprehensive detention and facility management services at Camp East Montana, including secure housing, medical care, transportation, and compliance with ICE National Detention Standards 2025.”[86]

The Trump administration argued that the sole source award was “necessary to maintain uninterrupted detention operations following the termination of the incumbent contract, ensuring ICE’s statutory mandate for the custody and removal of individuals subject to immigration proceedings,” and the administration claimed “no other vendor possesses the necessary rights or operational control to provide uninterrupted services at this location.”[87]

AMENTUM – HEALTH, SAFETY & REGULATORY VIOLATIONS

The company, however, and its affiliated businesses have a sordid history of complying with federal regulations governing a host of issues, including violating basic worker health and safety conditions and appropriate labor practices. Time will tell if they can meet the challenge of performing responsibly on this project. However, a review of past regulatory violations by Amentum and its affiliated companies presents a bleak picture of vast improvements at Camp East Montana.

In total, Amentum and its affiliated and acquired companies have accumulated 112 regulatory violations and paid more than $94 million in penalties since the year 2000, according to Violation Tracker.[88] This includes $56 million in nine instances of government contracting offenses, $32 million in 57 instances of employment-related offenses, $3.8 million in 42 safety related violations, including eight nuclear safety violations, and $2.4 million in five separate employment discrimination cases.[89]

Since the year 2000, Amentum Services Inc., and subsidiaries of its parent company, Amentum Holdings, Inc., have been cited and fined more than $500,000 for worker health and safety violations by the Occupational Safety and Health Administration (OSHA), that includes more than $125,000 over the past six years alone. Since 2020, Amentum and its subsidiaries have been cited for one dozen health and safety violations in nine separate incidents, including one fatality, according to OSHA records.[90] One 2023 incident involved the potential exposure of workers at the Central Intelligence Agency’s (CIA’s) headquarters in Virginia to toxic diphenylmethane diisocyanate vapors.[91] Another incident in 2024, involved a fatality at Fort Belvoir, in Virginia. [92]

These sorts of health and safety related incidents are particularly relevant to Amentum’s new contract to oversee the 5,000-bed immigration detention center at Camp East Montana that has already had at least one worker fatality and three detainee fatalities at the site in the first six months of its operation.

Legacy of Discriminatory Practices by Amentum Affiliated Companies

In 2019, the year before it became affiliated with Amentum, Washington River Protection Solutions (WRPS), the Department of Energy’s Office of Federal Contract Compliance Programs conducted an investigation and found that WRPS had discriminated against 151 Hispanic applicants who sought positions as health physics technician trainees with the company. The company did not admit liability, but in December 2022, agreed to pay $157,000 in back wages to the 151 Hispanic applicants in a settlement with the Department of Labor.[93]

In January 2020, AECOM Management Services, Inc. was rebranded Amentum. In September 2021, the company paid a $205,000 penalty for employment discrimination against 67 affected black applicants for “Aircraft Worker” positions in Virginia Beach, Virginia regarding their hiring process as part of a conciliation agreement with the Department of Labor’s Office of Federal Contract Compliance Programs.[94] On March 14, 2023, the company made its last distribution of funds to eligible applicants in this case.

Separately, in August 2020, AECOM Management Services, Inc. paid a $350,000 penalty as part of a conciliation agreement with the Department of Labor’s Office of Federal Contract Compliance Programs regarding its discriminatory hiring practices against 582 African-American and female applicants for Motor Equipment Metal Mechanic positions at the Red River Army Depot in Texarkana, Texas, between March 2013 and March 2015.[95]

On February 11, 2026, Bobby White, an African-American man, filed a civil rights complaint against Amentum Services Inc. in the U.S. District Court for the Northern District of Alabama, alleging that they engaged in unlawful, discriminatory and retaliatory employment practices.[96] White has worked for Amentum since November 2014 at the U.S. Army Depot in Anniston, Alabama, and worked at the facility for other contractors prior to that time.

False Claims Act & Related Violations

Although Amentum Services, Inc. has not been cited for False Claims Act or related violations itself, several of its related companies, that are subsidiaries of Amentum Holdings, Inc., have been cited for False Claims Act violations over the years, amounting to total fines or civil suits of more than $57 million.[97]

In April 2025, DynCorp International, LLC, acquired by Amentum in November 2020,[98] agreed to a $21 million Department of Justice (DOJ) settlement related to False Claims Act violations for knowingly billing the Department of State with inflated costs on a contract to train Iraqi police forces.[99] In a separate case in June 2025, Washington River Protection Solutions (WRPS), another Amentum subsidiary, agreed to pay $6.5 million to resolve allegations of fraud related to the company’s overcharging of labor hours involving millions of dollars on a Department of Energy contract.[100]

Table 1: Amentum Affiliated Companies’ False Claims Act & Related Violations[101]

Amentum Subsidiary or Affiliated Company	Primary Offense	Federal Agency	Year	Fine
DynCorp International LLC	False Claims Act and related offenses	DOJ Civil	2025	$21,000,000
Washington River Protection Solutions LLC	False Claims Act and related offenses	USAO/DOJ	2025	$6,500,000
DynCorp International LLC	Kickbacks & Bribery	USAO/DOJ	2020	$1,500,000
PAE Applied Technologies LLC	False Claims Act and related offenses	USAO/DOJ	2019	$4,200,000
Washington Closure Hanford LLC	False Claims Act and related offenses	USAO/DOJ	2018	$3,200,000
Washington River Protection Solutions LLC	False Claims Act and related offenses	DOJ Civil	2017	$5,275,000
Pacific Architechs and Engineers LLC	False Claims Act and related offenses	USAO/DOJ	2017	$5,000,000
PAE Government Service Inc. and RM Asia (HK) Limited	False Claims Act and related offenses	DOJ Civil	2015	$1,450,000
DynCorp International LLC	False Claims Act and related offenses	DOJ Civil	2011	$7,700,000
EG&G Technical Solutions, Inc.	False Claims Act and related offenses	USAO/DOJ	2009	$1,765,164
TOTAL				$57,590,164

TIES THAT BIND

Acquisition Logistics LLC and its senior officials do not appear to have any public ties to President Trump or his family and have not made any contributions to any of Trump’s political campaigns, based on a review of Federal Election Commission (FEC) data.

However, Nathan Albers, owner of Disaster Management Group (DMG) that is cited as one of the Acquisition Logistics subcontractors on the Camp East Montana project, has made substantial political donations to Republican political campaigns, including more than $150,000 in 2025 alone.[102] In addition, he and his wife have close ties to Trump’s family, according to public records. The Albers’ reportedly attended election night in 2024 at Mar-a-Lago and Nathan Albers once reportedly co-chaired a charity fundraiser at Trump National Golf Club with Eric and Lara Trump, according to reporting from ProPublica.[103] Albers also reportedly attended the “Crypto Ball” sponsored by supporters of Donald Trump in January 2025.[104] In early March 2026, Kimberly Albers also co-chaired a pet fundraiser at Mar-a-Largo with Lara Trump, the President’s daughter-in-law.[105]

Disaster management has been good for Nathan Albers. He appears to have profited handsomely from his various government contracts. In October 2024, it was reported that he purchased an 8,000 square foot waterfront mansion for $30 million on the Jupiter Inlet in Florida, about 24 miles north of Mar-a-Lago.[106] In addition, Albers’ personal connections to the Trump family raise questions about how his company, Disaster Management Group became involved with the DHS contract at Camp East Montana, particularly given the fact that DMG was fined $17.7 million in six separate incidents by the Department of Labor for wage and hour violations between 2021 and 2024.[107]

Since at least 2023, Kimberly Albers has been involved in a pet donation charity called Big Dog Ranch Rescue and their annual event at Mar-A-Lago. Kimberly and Nathan Albers, along with Eric Trump (President Trump’s son), and his wife Lara Trump posed for a photograph together at this event in 2023.[108]

In April 2024, Kimberly Albers also posted a photo on Instagram posing alongside Kimberly Guilfoyle, Donald Trump, Jr.’s former fiancée,[109] who was appointed by Donald Trump to be the U.S. Ambassador to Greece, and was confirmed by the U.S. Senate for that position in September 2025.[110]

From Friday, March 6^th to Sunday, March 8, 2026, Kim Albers co-chaired a “Wine, Women and Shoes” fundraising event for the Big Dog Rescue Ranch charity at Mar-A-Lago. Lara Trump served as the honorary chair of the event.[111]

It is unclear if Albers’ company, DMG, has any role in the new Camp East Montana contract with Amentum. Despite assertions by DHS that “no other vendor” was capable of fulfilling the contract except Amentum, questions remain about how and why it received the contract and why it was not opened up to a competitive bidding process.

There do not appear to be close political ties between Amentum and Donald Trump. However, the owner of one of the major companies that Amentum purchased in 2020, DynCorp International, has had very close ties to President Trump. In 2010, Cerberus Capital Management acquired DynCorp. for $1.5 billion.[112] Cerberus’ co-Chief Executive Officer (CEO), Stephen Feinberg, has been an active supporter of Donald Trump.[113] During the 2016 and 2020 Presidential elections Feinberg reportedly donated a reported $3.2 million to pro Trump PACs.[114] In addition, during Donald Trump’s run for the Presidency in 2016, Feinberg served on Trump’s Economic Advisory Council.[115] In May 2018, President Trump named Feinberg the Chair of the President’s Intelligence Advisory Board.[116] More recently, during his second term in office, President Trump nominated Feinberg to be the Deputy Secretary of Defense and he was sworn into that position in March 2025.[117] He is seen below seated next to Defense Secretary Pete Hegseth.

To be clear, Feinberg has not maintained any official positions with Amentum since they purchased DynCorp. Records also show that Amentum has not contributed to any of Donald Trump’s political campaigns. However, Amentum’s CEO, John Heller, personally met with Trump in September 2025 in the United Kingdom during Trump’s state visit to the U.K. During that visit Heller announced that Amentum would create 3,000 new jobs in the U.K.’s nuclear power industry and the company said in a press release and social media post on X, that they hoped Amentum could help “deliver on President Trump’s executive orders calling for a quadrupling of nuclear generating capacity by 2050.”[118] It is not known if Heller and Trump discussed the Camp East Montana facility during their meeting in the United Kingdom.

Conclusion

Camp East Mountain is a case study in the reckless cruelty of the Trump administration’s mass detention and deportation agenda. In service of a commitment to arrest and deport huge numbers of people, the administration is rushing to create a physical infrastructure sufficient to manage a surge of detainees. In doing so, it is cutting corners – and the horrific, and sometimes deadly, results are already evident.

The administration entered into a contract with Acquisition Logistics, a company with no experience operating at the scale of the Camp East Montana project, rushing forward in violation of normal contracting rules, and paving the way for avoidable human tragedy. Now it has replaced its first, failed contractor with a new, no-bid contract conferred on an enterprise that has compiled a sordid record of wrongdoing.

The detainee population at Camp East Montana is expected to eventually grow from an estimated 3,000 detainees today to 5,000 detainees when the center is at full capacity.[119] That will inevitably lead to more management and operational challenges and will likely lead to more problems, safety, health and security concerns regarding the detainee population, not less.

Unfortunately, Amentum’s past actions do not provide confidence that it will ensure that the people who are and will be detained at Camp East Montana – most of whom will not be criminals, contrary to administration claims, and many of whom may have legal right to be in the United States – receive decent and humane treatment they deserve.

Endnotes:

[1] Acquisition Logistics LLC, Contract Award Summary for ICE Detention Center, Ft. Bliss, Texas, Department of Defense (DOD), U.S. Army, USASPENDING.GOV (July 19, 2025), https://www.usaspending.gov/award/CONT_AWD_W9124J25FA075_9700_N0002325D0004_9700

[2] Kimmy Yam, “Japanese American groups blast use of Fort Bliss, former internment camp site, as ICE detention center,” NBC NEWS (August 20, 2025), https://www.aol.com/japanese-american-groups-blast-fort-194449232.html

[3] Acquisition Logistics LLC, Contract Award Summary for ICE Detention Center, Ft. Bliss, Texas, Department of Defense (DOD), U.S. Army, USASPENDING.GOV (July 19, 2025), https://www.usaspending.gov/award/CONT_AWD_W9124J25FA075_9700_N0002325D0004_9700

[4] Acquisition Logistics LLC, Indefinite Delivery / Indefinite Quantity (IDIQ) Contract, Department of Defense (DOD), U.S. Department of the Navy, USASPENDING.GOV (January 1, 2025), https://www.usaspending.gov/award/CONT_IDV_N0002325D0004_9700

[5] Amentum Services Inc., Camp East Montana Contract Award Summary, Department of Homeland Security (DHS), SAM.GOV (March 11, 2026), https://sam.gov/workspace/contract/opp/a8f590826172447b85036a8777b2cdd5/view

[6] Amentum Services Inc. search, Public Access To Court Electronic Records (PACER), https://pcl.uscourts.gov/

[7] Amentum Government Services Holdings LLC (now renamed Amentum Holdings Inc.), VIOLATION TRACKER, https://violationtracker.goodjobsfirst.org/?company_op=starts&company=amentum

[8] TEXAS SECRETARY OF STATE, https://www.sos.state.tx.us/corp/sosda/index.shtml

[9] “Competition in Contracting Act of 1984,” CONGRESS.GOV, https://www.congress.gov/bill/98th-congress/house-bill/5184

[10] Opinion and Order, Gemini Tech Services, LLC vs. The United States and Acquisition Logistics LLC, UNITED STATES COURT OF FEDERAL CLAIMS No. 25-1337C (issued under seal September 8, 2025 and reissued for publication on September 18, 2025), https://www.casemine.com/judgement/us/68ce63548edb569a8a375455

[11] Acquisition Logistics LLC search, Public Access To Court Electronic Records (PACER), https://pcl.uscourts.gov/

[12] Kristian Jaime, “Subcontractor employee death sparks OSHA investigation in Fort Bliss ICE facility,” EL PASO TIMES (August 22, 2025), https://www.elpasotimes.com/story/news/immigration/2025/08/22/osha-army-probe-fatal-incident-at-fort-bliss-immigration-facility/85782326007/

[13] Jesús Jank Curbelo, “The black hole of Camp East Montana: Three deaths in 44 days at the largest migrant detention center in the US,” EL PAIS (January 21, 2026), https://english.elpais.com/usa/2026-01-21/the-black-hole-of-camp-east-montana-three-deaths-in-44-days-at-the-largest-migrant-detention-center-in-the-us.html

[14] Ibid.

[15] Disaster Management Group LLC, VIOLATION TRACKER, https://violationtracker.goodjobsfirst.org/?company_op=starts&company=disaster+management

[16] Joseph Konig, “Immigration detention camp billed as the largest in U.S. history officially opens at Texas' Fort Bliss,” SPECTRUM NEWS (August 19, 2025), https://spectrumlocalnews.com/us/snplus/news/2025/08/19/fort-bliss-lone-star-lockup-texas-immigration-detention-military

[17] Base International Inc., FLORIDA DIVISION OF CORPORATIONS, https://search.sunbiz.org/Inquiry/CorporationSearch/SearchResultDetail?inquirytype=EntityName&directionType=Initial&searchNameOrder=BASEINTERNATIONAL%20F240000031220&aggregateId=forp-f24000003122-09b7373a-461b-44d8-9461-8bf5cf30c282&searchTerm=base%20international&listNameOrder=BASEINTERNATIONAL%20F240000031220

[18] Avi Asher-Schapiro and Jeff Ernsthausen, “His Former Company Got Caught Employing Undocumented Workers. Now He’s Profiting Off an Immigrant Detention Camp,” PROPUBLICA (July 25, 2025), https://www.propublica.org/article/nathan-albers-fort-bliss-immigration

[19] “Big Dog Ranch Rescue Raises Record Breaking $5.5 Million At Fundraiser,” TOWN-CRIER (March 20, 2026), https://gotowncrier.com/2026/03/big-dog-ranch-rescue-raises-record-breaking-5-5-million-at-fundraiser/

[20] “Treasure Coast Corporation and Corporate Officers Charged with Conspiring to Conceal and Harbor Aliens for the Purpose of Commercial Advantage,” U.S. Attorney’s Office, Southern District of Florida, DEPARTMENT OF JUSTICE (July 12, 2019), https://www.justice.gov/usao-sdfl/pr/treasure-coast-corporation-and-corporate-officers-charged-conspiring-conceal-and-harbor

[21] “Treasure Coast Corporation and Corporate Officers Sentenced Federally for Conspiring to Conceal and Harbor Aliens for the Purpose of Commercial Advantage or Private Financial Gain,” U.S. Attorney’s Office, Southern District of Florida, DEPARTMENT OF JUSTICE (December 20, 2019), https://www.justice.gov/usao-sdfl/pr/treasure-coast-corporation-and-corporate-officers-sentenced-federally-conspiring

[22] Peter Johansson, “How a $1.2 Billion Army Award to a Small Contractor Created a Fort Bliss Detention Controversy, DEFENSE-AEROSPACE (September 21, 2025), https://www.defense-aerospace.com/how-a-1-2-billion-army-award-to-a-small-contractor-created-a-fort-bliss-detention-controversy/

[23] Acquisition Logistics LLC, Contract Award Summary for ICE Detention Center, Ft. Bliss, Texas, Department of Defense (DOD), U.S. Army, USASPENDING.GOV (July 19, 2025), https://www.usaspending.gov/award/CONT_AWD_W9124J25FA075_9700_N0002325D0004_9700

[24] Acquisition Logistics LLC, Contract Award Summary for ICE Detention Center, Transfer to DHS/ICE, Ft. Bliss, Texas, Department of Defense (DOD), U.S. Army, USASPENDING.GOV (November 14, 2025),  https://www.usaspending.gov/award/CONT_AWD_70CDCR26FR0000001_7012_N0002325D0004_9700

[25] Acquisition Logistics LLC, Indefinite Delivery / Indefinite Quantity (IDIQ) Contract, Department of Defense (DOD), U.S. Department of the Navy, USASPENDING.GOV (January 1, 2025), https://www.usaspending.gov/award/CONT_IDV_N0002325D0004_9700

[26] Acquisition Logistics LLC, VIRGINIA STATE CORPORATION COMMISSION, https://cis.scc.virginia.gov/EntitySearch/BusinessInformation?businessId=518220&source=FromEntityResult&isSeries%20=%20false.

[27] Ibid. Kenneth Alan Wagner was born on January 14, 1948, in Fort Lewis, Washington. He comes from a military family. His father, Dale Gordon Wagner, was a Chief Master Sergeant in the U.S. Air Force, who served in World War II, Korea, and Vietnam. His father died in 2016 at the age of 96 years old. Wagner’s mother, Emma Josefa Rodriguez Wagner was born in Mayaguez, Puerto Rico in 1916 and died at the age of 86 in 2002 in Florida. Wagner’s parents appear to have met in Puerto Rico when Dale Wagner was stationed there during World War II, and they were married in November 1945 in Mayaguez, Puerto Rico, according to Ancestry.com records.

[28] Acquisition Logistics, ZOOMINFO, https://www.zoominfo.com/c/the-acquisition-logistics-co/355452231

[29] Acquisition Logistics, LLC, ROCKETREACH, https://rocketreach.co/acquisition-logistics-llc-management_b40c4f37ffc1eb8e

[30] Acquisition Logistics Support Group, LLC, Automatically Canceled, Registration Fee, STATE CORPORATION COMMISSION, COMMONWEALTH OF VIRGINIA, https://cis.scc.virginia.gov/EntitySearch/BusinessFilings

[31] Michael Biesecker and Joshua Goodman, “Mystery surrounds $1.2 billion Army contract for huge detention camp in Texas desert,” ASSOCIATED PRESS (August 28, 2025), https://www.nbcdfw.com/news/national-international/mystery-army-contract-detention-camp-texas-desert/3911185/

[32] Opinion and Order, Gemini Tech Services, LLC v. The United States and Acquisition Logistics LLC, UNITED STATES COURT OF FEDERAL CLAIMS, (filed under seal on September 8, 2025, reissued for publication on September 18, 2025), https://dockets.justia.com/docket/federal-claims/cofce/1:2025cv01337/52683

[33] Acquisition Logistics LLC, Contract Award Summary for ICE Detention Center, Transfer to DHS/ICE, Ft. Bliss, Texas, Department of Defense (DOD), U.S. Army, USASPENDING.GOV (November 14, 2025),  https://www.usaspending.gov/award/CONT_AWD_70CDCR26FR0000001_7012_N0002325D0004_9700

[34] Enemy Alien Internment in Texas during World War II, TEXAS HISTORICAL COMMISSION (August 2020), https://www.thc.texas.gov/public/upload/publications/Alien_Enemy_Brochure_08_20.pdf

[35] Ibid.

[36] Omar Ornelas, “Photos of Camp East Montana, controversial ICE facility in El Paso,” EL PASO TIMES, (October 13, 2025) https://www.elpasotimes.com/picture-gallery/news/immigration/2025/10/13/camp-east-montana-photo-gallery-of-ice-immigration-detention-facility-fort-bliss-el-paso-texas/86616916007/

[37] Gemini Tech Services, LLC (W911SE-2372), Bid Protest, GOVERNMENT ACCOUNTABILITY OFFICE (GAO) (July 28, 2025), https://www.gao.gov/docket/b-423775.1#:~:text=Posted%20on%20Sep%2009%2C%202025,Culliton

[38] Opinion and Order, Gemini Tech Services, LLC v. The United States and Acquisition Logistics LLC, UNITED STATES COURT OF FEDERAL CLAIMS, (filed under seal on September 8, 2025, reissued for publication on September 18, 2025), https://dockets.justia.com/docket/federal-claims/cofce/1:2025cv01337/52683

[39] Ibid.

[40] Ibid.

[41] Ibid.

[42] Ibid.

[43] Ibid.

[44] Presidential Executive Order 14159, Protecting the American People Against Invasion, THE WHITE HOUSE (January 20, 2025), https://www.whitehouse.gov/presidential-actions/2025/01/protecting-the-american-people-against-invasion/

[45] Opinion and Order, Gemini Tech Services, LLC v. The United States and Acquisition Logistics LLC, UNITED STATES COURT OF FEDERAL CLAIMS, (filed under seal on September 8, 2025, reissued for publication on September 18, 2025), https://dockets.justia.com/docket/federal-claims/cofce/1:2025cv01337/52683

[46] Ibid.

[47] Ibid.

[48] Ibid.

[49] Ibid.

[50] Acquisition Logistics LLC, Contract Award Summary for ICE Detention Center, Transfer to DHS/ICE, Ft. Bliss, Texas, Department of Defense (DOD), U.S. Army, USASPENDING.GOV (November 14, 2025),  https://www.usaspending.gov/award/CONT_AWD_70CDCR26FR0000001_7012_N0002325D0004_9700

[51] Natalie Venegas, “Amentum Services named new contractor for Camp East Montana detention center.” KFOX14 News (March 16, 2026), https://kfoxtv.com/news/local/amentum-services-named-new-contractor-for-el-pasos-camp-east-montana-detention-center

[52] “Mystery surrounds $1.2 billion Army contract to build huge detention tent camp in Texas desert,” PBS NEWS (August 28, 2026), https://www.pbs.org/newshour/politics/mystery-surrounds-1-2-billion-army-contract-to-build-huge-detention-tent-camp-in-texas-desert

[53] Public Citizen conversation with Texas Secretary of State official on March 27, 2026.

[54] “Foreign or Out-of-State Entities,” TEXAS SECRETARY OF STATE’S OFFICE, accessed March 20, 2026, https://www.sos.state.tx.us/corp/foreign_outofstate.shtml

[55] Avi Asher-Schapiro and Jeff Ernsthausen, “His Former Company Got Caught Employing Undocumented Workers. Now He’s Profiting Off an Immigrant Detention Camp,” PROPUBLICA (July 25, 2025), https://www.propublica.org/article/nathan-albers-fort-bliss-immigration

[56] “Nearly $16M in wages, benefits recovered for more than 2,800 workers denied full pay by 62 subcontractors on federal project at New Jersey military base,” DEPARTMENT OF LABOR, Wage and Hour Division (January 29, 2024), https://www.dol.gov/newsroom/releases/whd/whd20240129

[57] Disaster Management Group LLC, VIOLATION TRACKER, https://violationtracker.goodjobsfirst.org/?company_op=starts&company=disaster+management

[58] Articles of Organization for Disaster Management Group, LLC, FLORIDA DIVISION OF CORPORATIONS (February 6, 2006) https://search.sunbiz.org/Inquiry/CorporationSearch/ConvertTiffToPDF?storagePath=COR%5C2006%5C0213%5C90473969.Tif&documentNumber=L06000013077

[59] Premier Party Rentals, Inc. 2007 For Profit Corporation Annual Report, FLORIDA DIVISON OF CORPORATIONS (January 9, 2007), https://search.sunbiz.org/Inquiry/CorporationSearch/ConvertTiffToPDF?storagePath=COR%5C2007%5C0109%5C20797192.tif&documentNumber=P96000032997

[60] Articles of Amendment, Name Change from Premier Party Rentals, Inc. to TentLogix, Inc. FLORIDA DIVISION OF CORPORATIONS (July 30, 2010), https://search.sunbiz.org/Inquiry/CorporationSearch/ConvertTiffToPDF?storagePath=COR%5C2010%5C0805%5C00173278.Tif&documentNumber=P96000032997

[61] “Treasure Coast Corporation and Corporate Officers Charged with Conspiring to Conceal and Harbor Aliens for the Purpose of Commercial Advantage,” U.S. Attorney’s Office, Southern District of Florida, DEPARTMENT OF JUSTICE (July 12, 2019), https://www.justice.gov/usao-sdfl/pr/treasure-coast-corporation-and-corporate-officers-charged-conspiring-conceal-and-harbor

[62] “Treasure Coast Corporation and Corporate Officers Sentenced Federally for Conspiring to Conceal and Harbor Aliens for the Purpose of Commercial Advantage or Private Financial Gain,” U.S. Attorney’s Office, Southern District of Florida, U.S. DEPARTMENT OF JUSTICE (December 20, 2019), https://www.justice.gov/usao-sdfl/pr/treasure-coast-corporation-and-corporate-officers-sentenced-federally-conspiring

[63] “Treasure Coast Corporation and Corporate Officers Sentenced Federally for Conspiring to Conceal and Harbor Aliens for the Purpose of Commercial Advantage or Private Financial Gain,” U.S. Attorney’s Office, Southern District of Florida, DEPARTMENT OF JUSTICE (December 20, 2019), https://www.justice.gov/usao-sdfl/pr/treasure-coast-corporation-and-corporate-officers-sentenced-federally-conspiring

[64] Christopher Bokum, “TentLogix Files for Chapter 11 Bankruptcy Following 2019 Indictment,” LEVELSET.COM (July 30, 2021), https://www.levelset.com/news/tentlogix-chapter-11-bankruptcy/

[65] Acquisition Logistics LLC, Contract Award Summary for ICE Detention Center, Ft. Bliss, Texas, Department of Defense (DOD), U.S. Army, USASPENDING.GOV (July 19, 2025), https://www.usaspending.gov/award/CONT_AWD_W9124J25FA075_9700_N0002325D0004_9700

[66] Acquisition Logistics LLC, Inspection: 1859269.015, Accident: 2323120, OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION (OSHA) (July 21, 2025), https://www.osha.gov/ords/imis/establishment.inspection_detail?id=1859269.015

[67] JMJ Production Services, LLC, Inspection: 11840556.015, OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION (OSHA) (July 21, 2025), https://www.osha.gov/ords/imis/establishment.inspection_detail?id=1840556.015

[68] Fulfillment Personnel Services, LLC, Inspection: 1840555.015, OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION (OSHA) (July 21, 2025), https://www.osha.gov/ords/imis/establishment.inspection_detail?id=1840555.015

[69] Base International Inc., Inspection: 1838708.015, OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION (OSHA) (July 21, 2025), https://www.osha.gov/ords/imis/establishment.inspection_detail?id=1838708.015

[70] Base International Inc., FLORIDA DIVISION OF CORPORATIONS, https://search.sunbiz.org/Inquiry/CorporationSearch/SearchResultDetail?inquirytype=EntityName&directionType=Initial&searchNameOrder=BASEINTERNATIONAL%20F240000031220&aggregateId=forp-f24000003122-09b7373a-461b-44d8-9461-8bf5cf30c282&searchTerm=base%20international&listNameOrder=BASEINTERNATIONAL%20F240000031220

[71] Joseph Konig, “Immigration detention camp billed as the largest in U.S. history officially opens at Texas' Fort Bliss,” SPECTRUM NEWS (August 19, 2025), https://spectrumlocalnews.com/us/snplus/news/2025/08/19/fort-bliss-lone-star-lockup-texas-immigration-detention-military

[72] Base International Inc., Inspection: 1838708.015, OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION (OSHA) (July 21, 2025), https://www.osha.gov/ords/imis/establishment.inspection_detail?id=1838708.015

[73] Hector Horacio Gonzalez (March 27, 1987-July 21, 2025), Obituary, LEGACY.COM, https://www.legacy.com/us/obituaries/name/hector-gonzalez-memorial?id=58984806

[74] JMJ Production Services, LLC, Inspection: 11840556.015, OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION (OSHA) (July 21, 2025), https://www.osha.gov/ords/imis/establishment.inspection_detail?id=1840556.015

[75] Fulfillment Personnel Services, LLC, Inspection: 1840555.015, OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION (OSHA) (July 21, 2025), https://www.osha.gov/ords/imis/establishment.inspection_detail?id=1840555.015

[76] Acquisition Logistics LLC, Inspection: 1859269.015, Accident: 2323120, OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION (OSHA) (July 21, 2025), https://www.osha.gov/ords/imis/establishment.inspection_detail?id=1859269.015

[77] “60 violations in 50 days: Inside ICE’s giant tent facility at Ft. Bliss,” THE WASHINGTON POST (September 16, 2025), https://www.washingtonpost.com/business/2025/09/16/ice-detention-center-immigration-violations/

[78] Morgan Lee, Ryan J. Foley and Michael Biesecker, “‘Worse than a prison': 911 calls, interviews reveal problems at ICE’s largest detention camp,” ASSOCIATED PRESS (March 6, 2026), https://apnews.com/article/ice-detention-camp-conditions-911-calls-738c63a2b96a90c2f85a668ec2fd3b5b

[79] Jesús Jank Curbelo, “The black hole of Camp East Montana: Three deaths in 44 days at the largest migrant detention center in the US,” EL PAIS (January 21, 2026), https://english.elpais.com/usa/2026-01-21/the-black-hole-of-camp-east-montana-three-deaths-in-44-days-at-the-largest-migrant-detention-center-in-the-us.html

[80] Colleen DeGuzman, “Immigrant’s death in ICE custody ruled homicide by El Paso medical examiner,” THE TEXAS TRIBUNE (January 21, 2026), https://www.texastribune.org/2026/01/21/texas-el-paso-immigrant-death-ice-custody-homicide/

[81] Ibid.

[82] Laura Strickler and Daniel Arkin, “Third immigrant detainee at facility in El Paso has died, ICE says,” NBC NEWS (January 19, 2026), https://www.nbcnews.com/news/us-news/third-immigrant-detainee-facility-el-paso-died-ice-says-rcna254783

[83] Amentum: About Us, AMENTUM.COM, https://www.amentum.com/

[84] “Amentum Completes Transformational Combination with Jacobs’ Critical Mission Solutions and Cyber and Intelligence Units,” Press Release, AMENTUM.COM, (September 27, 2024), https://www.amentum.com/news/amentum-completes-transformational-combination-with-jacobs-critical-mission-solutions-and-cyber-and-intelligence-units/

[85] Amentum Services Inc., Camp East Montana Contract Award Summary, Department of Homeland Security (DHS), SAM.GOV (March 11, 2026), https://sam.gov/workspace/contract/opp/a8f590826172447b85036a8777b2cdd5/view

[86] Ibid.

[87] Ibid.

[88] Amentum Government Services Holdings LLC, Violation Tracker, https://violationtracker.goodjobsfirst.org/parent/amentum-government-services-holdings-llc

[89] Ibid.

[90] Ibid.

[91] Amentum, Inspection: 1654142.015, Incident Occurrence, February 16, 2023, OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION (OSHA) (March 1, 2023), https://www.osha.gov/ords/imis/establishment.inspection_detail?id=1654142.015

[92] Amentum Services, Inc., Inspection: 1767588.015, Incident Occurrence, August 6, 2024, OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION (OSHA) (August 8, 2024), https://www.osha.gov/ords/imis/establishment.inspection_detail?id=1767588.015

[93] “US Department of Labor reaches agreement with environmental cleanup provider to resolve alleged hiring discrimination at Richland’s Hanford Site,” Press Release, Office of Federal Contract Compliance Program, U.S. DEPARTMENT OF LABOR (December 8, 2022), https://www.dol.gov/newsroom/releases/ofccp/ofccp20221208

[94] See: AECOM Management Services, Inc. (Parent Company: Amentum Government Services Holdings LLC), VIOLATION TRACKER (September 30, 2021), https://violationtracker.goodjobsfirst.org/violation-tracker/va-aecom-management-services-inc and Conciliation Agreement Between the Department of Labor Office of Federal Contract Compliance Programs and AECOM Management Services, Inc., DEPARTMENT OF LABOR (Undated), https://www.dol.gov/sites/dolgov/files/OFCCP/foia/files/2021-09-30AECOM301560MACA_Redacted.pdf

[95] See: AECOM Management Services, Inc. (Parent Company: Amentum Government Services Holdings LLC), VIOLATION TRACKER (August 10, 2020), https://violationtracker.goodjobsfirst.org/violation-tracker/tx-aecom-management-services-inc and Conciliation Agreement Between the U.S. Department of Labor Office of Federal Contract Compliance Programs and AECOM Management Services, Inc., Red River Army Depot, Texarkana, Texas, U.S. DEPARTMENT OF LABOR (August 10, 2020), https://www.dol.gov/sites/dolgov/files/ofccp/foia/files/2020-08-10AECOM_CA_SW_Redacted.pdf

[96] Bobby White vs. Amentum Services, Inc., Case 5:26-cv-00221-HDM, UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ALABAMA NORTHEASTERN DIVISION, (February 11, 2026).

[97] Amentum, VIOLATION TRACKER, https://violationtracker.goodjobsfirst.org/?company_op=starts&company=amentum

[98] “Amentum Closes DynCorp Acquisition,” Press Release, AMENTUM.COM (November 23, 2020), https://www.amentum.com/news/amentum-closes-dyncorp-acquisition/

[99] “DynCorp Agrees to Pay $21 Million to Resolve False Claims Act Lawsuit Alleging Inflated Costs on State Department,” U.S. Attorney’s Office, District of Columbia, U.S. DEPARTMENT OF JUSTICE (April 9, 2025), https://www.justice.gov/usao-dc/pr/dyncorp-agrees-pay-21-million-resolve-false-claims-act-lawsuit-alleging-inflated-costs

[100] “Hanford Contractor, Washington River Protection Solutions (WRPS), Agrees to Pay $6.5 Million to Resolve Allegations of Fraud,” U.S. Attorney’s Office, Eastern District of Washington, U.S. DEPARTMENT OF JUSTICE (June 24, 2025), https://www.justice.gov/usao-edwa/pr/hanford-contractor-washington-river-protection-solutions-wrps-agrees-pay-65-million

[101] Amentum, VIOLATION TRACKER, https://violationtracker.goodjobsfirst.org/?company_op=starts&company=amentum

[102] Avi Asher-Schapiro and Jeff Ernsthausen, “His Former Company Got Caught Employing Undocumented Workers. Now He’s Profiting Off an Immigrant Detention Camp,” PROPUBLICA (July 25, 2025), https://www.propublica.org/article/nathan-albers-fort-bliss-immigration

[103] Avi Asher-Schapiro and Jeff Ernsthausen, “His Former Company Got Caught Employing Undocumented Workers. Now He’s Profiting Off an Immigrant Detention Camp,” PROPUBLICA (July 25, 2025), https://www.propublica.org/article/nathan-albers-fort-bliss-immigration

[104] Ibid.

[105] “Big Dog Ranch Rescue Raises Record Breaking $5.5 Million At Fundraiser,” TOWN-CRIER (March 20, 2026), https://gotowncrier.com/2026/03/big-dog-ranch-rescue-raises-record-breaking-5-5-million-at-fundraiser/

[106] Kate Hinsche, “Disaster response mogul buys Jupiter Inlet Colony’s most expensive house for record $30M,” THE REAL DEAL (October 31, 2024), https://therealdeal.com/miami/2024/10/31/jupiter-inlet-colony-mansion-sells-for-record-30m/

[107] Disaster Management Group LLC, VIOLATION TRACKER, https://violationtracker.goodjobsfirst.org/?company_op=starts&company=disaster+management

[108] Big Dog Ranch Rescue, FACEBOOK post (December 13, 2023), https://www.facebook.com/photo/?fbid=750889880413783&set=pcb.750890327080405

[109] Brandon Bombay, “Kimberly Guilfoyle’s Closest Gal Pals at Mar-a-Lago Scream Desperate Housewives,” NICKI SWIFT.COM (December 22, 2024), https://www.nickiswift.com/1740178/kimberly-guilfoyle-pals-mar-a-lago-scream-desperate-housewives/

[110] “U.S. Senate Confirms Kimberly Guilfoyle as U.S. Ambassador to the Hellenic Republic,”
U.S. EMBASSY & CONSULATE IN GREECE (September 19, 2025), https://gr.usembassy.gov/press-release-u-s-senate-confirms-kimberly-guilfoyle-as-u-s-ambassador-to-the-hellenic-republic/

[111] Big Dog Ranch Rescue, WINE, WOMENT & SHOES, https://www.winewomenandshoes.com/event/bdrr/

[112] “Cerberus to Buy DynCorp for $1.5 Billion,” Dealbook, THE NEW YORK TIMES (April 12, 2010), https://archive.nytimes.com/dealbook.nytimes.com/2010/04/12/cerberus-to-buy-dyncorp-for-1-5-billion/

[113] Oligarchs and the Trump Admin: Stephen Feinberg,” REVOLVING DOOR PROJECT (April 8, 2025), https://therevolvingdoorproject.org/billionaires-and-the-trump-admin-stephen-feinberg/

[114]Matthew Cunningham-Cook, “Major Trump Donor Owned Security Firm That Trained Khashoggi Killers,” THE INTERCEPT (June 24, 2021), https://theintercept.com/2021/06/24/khashoggi-trump-donor-saudi-arabia-tier-1/

[115] Catherine Macaulay, “Who’s Who in Defense: Stephen Feinberg, Deputy Secretary of Defense (DSD),” BREAKING DEFENSE (April 1, 2025), https://breakingdefense.com/2025/04/whos-who-in-defense-stephen-feinberg-deputy-secretary-of-defense-dsd/

[116] Ibid.

[117] Ibid.

[118] “Amentum to create 3,000 jobs as U.K. nuclear renaissance and defence spending boost growth,” AMENTUM.COM (September 18, 2025), https://www.amentum.com/news/amentum-to-create-3000-jobs-as-u-k-nuclear-renaissance-and-defence-spending-boost-growth/

[119] Aaron Reichlin-Melnick, “ICE’s Warehouse Purchases Herald New Model for Immigration Detention,” AMERICAN IMMIGRATION COUNCIL (February 24, 2026), https://www.americanimmigrationcouncil.org/blog/ice-buys-warehouses-immigration-detention/?utm_source=chatgpt.com

As part of its mass detention and deportation project, the Trump administration is funding the construction and operation of detention centers around the country.

The surge in funding has created opportunities for corruption and profiteering by corporations with insider ties. The administration is awarding large contracts to businesses with little prior experience, as well as to more well-established corporations with dubious records, setting off alarm bells about the quality of construction and the treatment of detainees.

One major detention facility located on the grounds of Ft. Bliss in El Paso, Texas is known as Camp East Montana.[1] The 5,000-person facility is being built in the same location that housed Japanese-Americans in internment camps during World War II, and its construction has been condemned by Japanese-American and other groups.[2]

The administration first awarded a $1.3 billion contract to construct and operate the detention center to a company with no prior experience constructing or operating a detention facility, Acquisition Logistics LLC.[3] The contract has a financial ceiling of $2.7 billion.[4] Eight months after the contract was first awarded in July 2025, due to a litany of lethal and other problems, the Department of Homeland Security (DHS) replaced Acquisition Logistics with Amentum Services, Inc. Amentum Services, which has its own troubled history, received a no-bid, sole-sourced contract of an undetermined amount last month.[5]

Public Citizen’s investigation shows that DHS is replacing one troubled contractor with another company that has a history of engaging in multiple regulatory violations, particularly health and safety violations, which may endanger the thousands of detainees housed at Camp East Montana. In addition, some of the subcontractors tied to the Immigration and Customs Enforcement (ICE) facility at Ft. Bliss have been large donors to Republican campaigns and have close ties to the Trump family, raising questions about how some of these companies were selected in the first place. Deaths and disease infected Camp East Montana under the management of the previous contractor. It is unclear whether conditions at the facility will improve with the new contractor given its past challenges abiding by regulatory health and safety requirements.

Among Public Citizen’s key findings:

• The new DHS contractor, Amentum, has been a defendant in 40 lawsuits in federal court over the past eight years, involving false claims act, antitrust, wage and hour, and human trafficking allegations;[6]
• Over the past two decades, Amentum Holdings, Inc., the parent company of Amentum Services, Inc., and its other affiliated companies have been involved in at least 112 separate violations of U.S. regulations, including workplace safety and health violations, false claims act violations, wage and hour violations, and employment discrimination, nuclear safety, family and medical leave, labor relations, and environmental violations.[7]
• The company’s predecessor in running the same El Paso detention center, Acquisition Logistics, was never registered to operate in Texas, during the term of its contract in violation of Texas state law;[8]
• The U.S. Army, which transferred the Acquisition Logistics contract to DHS in November 2025 was found by a federal judge to have violated federal contracting regulations and the Competition in Contracting Act (CICA),[9] by not temporarily suspending the contract in July 2025, when a bid protest was filed with the Government Accountability Office (GAO) by Gemini Tech Service LLC;[10]
• Acquisition Logistics has been a respondent in seven lawsuits brought by detainees at the facility between September 2025 and February 2026.[11]
• One Acquisition Logistics subcontract worker, named Hector Gonzalez, died on site at Camp East Montana in an industrial truck related accident on July 21, 2025, two days after the Acquisition Logistics contract commenced;[12]
• At least three detainees also died at the Camp East Montana facility between December 2025 and January 2026;[13]
• One of those deaths was reportedly ruled a homicide by the El Paso County Medical Examiner’s office, and witnesses reported the individual had a physical confrontation with guards just prior to his death;[14]
• From 2021 to 2024, an Acquisition Logistics subcontractor at Camp East Montana, Disaster Management Group (DMG), was fined a total of $17.7 million, in six separate cases by the Department of Labor for wage and hour violations;[15]
• The worker who died at the facility in July 2025 was reported to have worked for DMG.[16] However, that worker may have actually worked for another company named Base International, Inc.[17] Both companies are owned by Nathan (“Nate”) Albers a close associate of the Trump family.[18] In early March 2026, Albers’s wife, Kimberly Albers, co-chaired a pet fundraiser at Mar-a-Lago along with Lara Trump;[19]
• In 2019, a separate Albers company, TentLogix was charged by the Department of Justice (DOJ) “with conspiring to conceal and harbor” 92 aliens for the purpose of commercial advantage by recruiting and employing individuals they knew had entered the country illegally.[20] Albers was not charged in the case, and has since left the company, but several of his TentLogix business partners served time in prison as a result of these unlawful actions and the company was placed on four years’ probation as part of a corporate compliance agreement with the Department of Justice.[21]

CAMP EAST MONTANA – CONTRACT

On June 9, 2025, the U.S. Army issued a solicitation notice for a contractor to build and operate a large immigration detention center in the Chihuahuan Desert at Fort Bliss in Texas.[22] The Army received 11 offers on the contract, and on July 18, 2025, the Army issued a firm-fixed-price contract award to Acquisition Logistics LLC to construct a 5,000-bed ICE detention facility at Ft. Bliss in El Paso, Texas, called Camp East Montana.[23] The contract has been widely reported as a $1.3 billion contract. However, that appears to be for a single task order of the contract.[24] USAspending.gov shows that the full indefinite delivery / indefinite quantity (IDIQ) contract has an actual ceiling price of $2.7 billion.[25]

The contract award raised immediate concerns. Acquisition Logistics, LLC, established in Virginia in 2008,[26] for instance, does not appear to have a main office and is registered to a home in Richmond, Virginia that is owned by Kenneth Alan Wagner, a retired Navy Commander, and the founder and owner of the company, according to Virginia Secretary of State records.[27] In addition, the company only has between 8 and 50 employees, according to ZoomInfo[28] and RocketReach,[29] making their successful management of a billion-dollar contract appear cumbersome at best given their size.

Acquisition Logistics LLC has a very limited public footprint. One available brochure says they focus on five key areas, program management, logistics and supply chain, acquisition support, engineering support, and technology integration.[30] They have had around 30 previous federal contracts with various agencies, including the U.S. Army, U.S. Navy, U.S. Marine Corps, Defense Logistics Agency, Federal Aviation Administration, and Department of the Interior. Their cumulative total federal contracts since 2008, excluding the recent billion-dollar contract, have been around $48 million, and the largest single contract was valued at $16 million.[31]

CONTRACT AWARD

 The U.S. Army’s contract to Acquisition Logistics was “to construct, operate, and maintain a new 5,000-capacity short-term detention facility at Fort Bliss, Texas … for single adults awaiting immigration proceedings or removal from the United States.”[32] This facility was named Camp East Montana, after the name of the road where it is situated, and the site began receiving detainees in August 2025. In November 2025, the contract was transferred from the Department of Defense to the Department of Homeland Security.[33]

During World War II Fort Bliss held Japanese-Americans and Italian and German prisoners of war.[34] Photos of the facility during World War II[35] in the 1940s and today are included below.[36]

CONTRACT BID PROTEST

 On July 28, 2025, ten days after the U.S. Army awarded the ICE detention contract to Acquisition Logistics, LLC, Gemini Tech Service LLC, based in Willow Park, Texas, filed a bid protest with the Government Accountability Office (GAO).[37] The Competition in Contracting Act (CICA), calls for a temporary “stay of contract performance” once a bid protest is lodged with the GAO. In this case, however, the U.S. Army determined that it would override the stay and on July 28, 2025, directed Acquisition Logistics to continue with the task order under the contract in violation of what is known as a “CICA stay.”[38] The U.S. Army also failed to notify GAO of its action until three days later, on July 31, 2025. On August 1, 2025, the Army issued a 10-page determination and findings (“D&F”) report regarding the contract and filed that with the GAO on August 4, 2025.[39]

On August 11, 2025, due to the Army’s actions, Gemini filed a lawsuit regarding the contract award with the United States Court of Federal Claims.[40] Gemini made three key allegations in their lawsuit: 1) that Acquisition Logistics failed to comply with two material solicitation requirements, proposing a final site design and failing to propose critical utilities; 2) the Army failed to evaluate the quality of offerors’ past performance; and 3) the Army’s “responsibility determination” was unreasonable.[41]

According to the court’s 18-page “Opinion and Order,” filed under seal on September 8, 2025, and publicly released on September 18, 2025:

“Although the Army corrected its error, the Court notes that by proceeding with the contract performance without first notifying GAO and executing a written determination, the Army violated the statute by failing to comply with the CICA stay which was in place.”[42]

The Army laid out its justification for violating the CICA in its D&F report. The Army argued that it had determined that there were “urgent and compelling circumstances which significantly affect interests of the United States [that] will not permit waiting for the decision of the GAO’s decision in the protest.”[43] The Army also noted that the contract aligned with priorities in President Trump’s Executive Order 14159, which directs for the efficient and expedited removal of aliens from the United States.[44]

In its D&F, the Army wrote:

“[A] continued stay will directly exacerbate the existing detention capacity crisis, hindering ICE’s ability to effectively manage the influx of detainee apprehensions. This will result in increased operational risks, potential legal challenges related to overcrowding, and a heightened strain on resources. The delay will also disrupt planned operational deployments and enforcement activities reliant on adequate detention capacity, directly impacting ICE’s core mission as outlined in the SOO [Statement of Objectives]. The current overcapacity situation is unsustainable and demands immediate action to ensure humane treatment, appropriate care, and legal compliance.”[45]

The U.S. Army’s D&F also argued:

“The Department of Homeland Security (OHS) reports 1.5 million active final removal orders, yet only 41,500 federally funded bed spaces are currently available, necessitating reliance on state- funded facilities to address the shortfall. Current detention facilities are critically overcrowded, housing 57,600 individuals. This overcrowding creates unsafe conditions for both U.S. Immigration and Customs Enforcement (ICE) agents and those in custody, increasing the risk of altercations, health crises, and potential security breaches. Failure to address this capacity gap poses significant operational, security, and humanitarian risks, demanding immediate attention and resolution. Therefore, the benefits of overriding the stay and proceeding with performance greatly outweigh the potential costs of not doing so.”[46] [Emphasis added].

In addition, the Army claimed, based on projections from Acquisition Logistics LLC, that temporarily halting the contract and construction work would add more than $500 million in additional costs.[47] It seems clear that the Army was arguing that these economic costs and their security concerns with temporarily suspending the Acquisition Logistics contract outweighed the requirements of abiding by the law and the Competition in Contracting Act, which required them to temporarily halt the contract once Gemini filed its bid protest with GAO.

The Army’s D&F argued, “Given the substantial progress already achieved by the current awardee and the nature of the work completed to date, transitioning performance to a new vendor would present significant logistical and operational challenges. Replicating the established infrastructure, personnel, and ongoing operational tempo would introduce unacceptable risk to mission continuity and potentially result in substantial delays and increased costs.”[48]

In the end, the court said it “was disappointed with the Army’s actions in this procurement,” but because it found there was a “reasonable basis for the Army’s decision” the court denied the plaintiff’s motion for a preliminary injunction and dismissed the complaint.[49]

The contract was transferred from the Department of Defense to the Department of Homeland Security in November 2025.[50] Ironically, DHS terminated the contract with Acquisition Logistics in mid-March 2026 due to a litany of problems and replaced it with a new contractor, Amentum, who had been a subcontractor under Acquisition Logistics on the project.[51]

The DHS contract Acquisition Logistics received was the first time they had obtained a DHS contract, and it was more than 81 times larger than any other contract they had ever managed. The largest previous contract they had won was widely reported to have been a $16 million federal contract.[52] The $1.3 billion DHS contract was more than 8,000% larger than their $16 million contract and it was 27 times larger than all other contracts the company had ever won combined.

TEXAS BUSINESS REGISTRATION

Although Acquisition Logistics LLC began operating in Texas in July 2025 to initiate the construction of Camp East Montana, the company failed to register with the Texas Secretary of State’s office in violation of Texas law. The company only attempted to register with the Texas Secretary of State’s office on March 19, 2026, after DHS had terminated their contract. However, according to an official with the Texas Secretary of State’s office the company’s registration was rejected on March 21, 2026, because they had improperly filed out the necessary registration form.[53]

Acquisition Logistics operated illegally in Texas for eight months. The Texas Secretary of State’s office says that failure to register for out-of-state entities may result in penalties, including:

• Inability to maintain an action, suit, or proceeding in a Texas court until registration;
• Injunction from transacting business in Texas;
• Civil penalty equal to all fees and taxes that would have been imposed if the entity had registered when first required; and
• Late filing fees owed to the secretary of state by an entity registering more than 90 days after first transacting business in Texas.[54]

ACQUISITION LOGISTICS – SECRECY

Secrecy has plagued both Acquisition Logistics LLC and its DHS contract. There has been no public release of any of Acquisition Logistics subcontractors, for instance, and the company’s own website (https://acq-log.com/) is hidden behind a virtual digital wall, where a password and logon is needed to access the site.

DISASTER MANAGEMENT GROUP (DMG) LLC

The company’s subcontracts have also been cloaked in secrecy. However, in July 2025, ProPublica reported that Disaster Management Group (DMG), LLC, owned by Nathan Albers, was one of Acquisition Logistics LLC’s subcontractors.[55] In January 2024, DMG signed a compliance agreement with the Department of Labor regarding worker wage violations at McGuire Air Force Base in New Jersey. The Department of Labor’s press release said:

“A widespread investigation by the U.S. Department of Labor has recovered nearly $16 million in back wages and restored over 24,700 paid sick leave hours to leave banks for more than 2,800 workers denied their full wages and benefits by 62 subcontractors hired to construct temporary housing and provide services to Afghan refuses at Joint Base McGuire-Dix-Lakehurst in New Jersey.

After 75 investigations that included Jupiter, Florida-based Disaster Management Group LLC, one of the project’s general contractors, and 61 subcontractors, the department’s Wage and Hour Division found DMG and its subcontractors violated [multiple] federal law[s].”[56]

In total, DMG was fined six times by the Department of Labor for wage and hour violations between 2021 and 2024, amounting to an additional $1.7 million in penalties.[57]

In 2006, Albers and Gary Hendry established Disaster Management Group, LLC together in Florida.[58] According to Florida Secretary of State records they remained co-owners and partners at DMG through 2019. Hendry appears to have left the company in 2020.

At the same time Hendry was running DMG with Albers, however, he was also running another industrial tent company called Premier Party Rentals, Inc. as the Chief Executive Officer (CEO) that he established in 1996 in Florida. In 2007, the year after Albers and Hendry established DMG, Albers also joined Premier Party Rentals, Inc.[59] On July 30, 2010, they changed the name to TentLogix, Inc.[60]

In July 2019, Hendry and two other TentLogix executives were charged “with conspiring to conceal and harbor aliens for the purpose of commercial advantage by recruiting and employing individuals they knew had entered the country illegally.[61] Hendry was also charged with making false statements. In December 2019, Hendry was sentenced to one year and one day in prison and ordered to forfeit $282,789 to the U.S. government and pay a $75,000 fine.[62] TentLogix was sentenced to four years’ probation and signed a corporate compliance agreement for employing 92 aliens that had entered the country illegally.[63] The company declared bankruptcy in November 2020 in U.S. Bankruptcy Court in the Southern District of Florida.[64] For his part, Albers was never charged with any crime and appears to have severed ties with TentLogix in 2019.

A FATAL ACCIDENT

The contract for Camp East Montana was troubled from the very start. Saturday, July 19, 2025, was the start date of the U.S. Army issued contract.[65] On Monday, July 21, 2025, just two days after the contract was underway there was a fatal accident at the Camp East Montana site involving Acquisition Logistics LLC,[66] JMJ Production Services,[67] Fulfillment Personnel Services,[68] and Base International Inc.,[69] a company established by Nathan Albers in Delaware in December 2023, that is also registered to operate in Florida.[70] The media has reported that the individual who died was a 38-year-old man named Hector Gonzalez, who was reportedly working for Albers’ other company, Disaster Management Group (DMG).[71] However, a search of Occupational Safety and Health Administration (OSHA) records does not identify any record for DMG, but it does identify Base International Inc. as being involved in the July 21^st accident.[72] An obituary posting on Legacy.com has a video montage celebrating a Hector Horacio Gonzalez, who was 38 years old and died on July 21, 2025, which matches the age of the Hector Gonzalez that died at Camp East Montana.[73] The video montage suggests that he had three daughters. However, there is no information about how he died or where he worked. As of April 6,  2026, the obituary says it is being updated.

The specifics of the accident are still unclear. However, Base International, JMJ Production Services, and Fulfillment Personnel Services were all cited by OSHA for not meeting industrial truck design, inspection, testing, maintenance, and operation standards. JMJ Production Services[74] and Fulfillment Personnel Services[75] were also cited for not certifying that each operator had been properly trained and evaluated. Both companies were cited for two separate “serious” OSHA violations, agreed to an informal settlement on February 18, 2026, and each company paid a reduced penalty of $15,000. Base International, Inc. was cited for violating the truck standards issue mentioned above, described by OSHA as a “serious” violation, but the company contested its $11,585 fine on February 13, 2026. The final OSHA fine regarding Base International appears to remain unresolved. The OSHA records do not show that Acquisition Logistics was cited for any specific violation or fined, but they do link Acquisition Logistics to the July 21, 2025, accident and OSHA records show that OSHA closed the case regarding Acquisition Logistics on January 21, 2026.[76]

DEATH OF DETAINEES

Besides the death of a worker at the site, multiple reports have shown that the health and safety of those detained at the Camp East Montana facility are in jeopardy. In September 2025, the Washington Post reported that an internal ICE report found the facility had 60 violations of ICE detention standards in just 50 days.[77] In early March 2026, the Associated Press reported that they had reviewed 130 emergency 911 calls from Camp East Montana between mid-August 2025 through January 20, 2026, that revealed at least six attempted suicide attempts, at least 20 seizures, some reportedly due to head trauma, and other medical traumas and mental health related emergencies.[78]

In addition, over a seven-week span from December 3, 2025, to January 15, 2026, three detainees died at the facility. Francisco Gaspar Andrés, age 48, from Guatemala died on December 3, 2025, after being hospitalized for two weeks at a local El Paso hospital. The initial cause of death was reported as “natural liver and kidney failure.”[79] Exactly one month later on January 3, 2026, Geraldo Lunas Campos, 55, from Cuba, died after a confrontation with Camp East Montana guards.[80] The El Paso County Medical Examiner’s office reportedly declared the death to be a homicide caused by asphyxia due to neck and torso injuries while being physically restrained, although ICE officials initially claimed he died after an attempted suicide.[81] Two weeks later, on January 15, 2026, a 36-year-old Nicaraguan man, Victor Manual Díaz, died from an apparent suicide.[82] He was found unconscious in his room by security staff and pronounced dead at the time he was discovered.

AMENTUM – BACKGROUND & CONTRACT JUSTIFICATION

Whether or not the new contractor, Amentum, that has been hired for just 180 days (six months) to take over the Acquisition Logistics contract will perform much better is unknown. Amentum is a much larger company. It has more than 50,000 employees in more than 70 countries and generated more than $14 billion in revenue in 2025 alone.[83]

Amentum was formed in 2020 as a spinoff of AECOM’s Management Services Group. In March 2024 they merged with Jacobs’ Critical Mission Solutions and Cyber and Intelligence business, and in September 2024 Amentum Government Services Holding became Amentum Holdings, Inc. merging Amentum Services, Inc. with Jacobs Solutions.[84]

On March 11, 2026, DHS issued a “notice of intent to award a sole source-contract” to Amentum Services, Inc. for “detention and facility management services at Camp East Montana.”[85] The new contract says, “Amentum Services Inc. will provide comprehensive detention and facility management services at Camp East Montana, including secure housing, medical care, transportation, and compliance with ICE National Detention Standards 2025.”[86]

The Trump administration argued that the sole source award was “necessary to maintain uninterrupted detention operations following the termination of the incumbent contract, ensuring ICE’s statutory mandate for the custody and removal of individuals subject to immigration proceedings,” and the administration claimed “no other vendor possesses the necessary rights or operational control to provide uninterrupted services at this location.”[87]

AMENTUM – HEALTH, SAFETY & REGULATORY VIOLATIONS

The company, however, and its affiliated businesses have a sordid history of complying with federal regulations governing a host of issues, including violating basic worker health and safety conditions and appropriate labor practices. Time will tell if they can meet the challenge of performing responsibly on this project. However, a review of past regulatory violations by Amentum and its affiliated companies presents a bleak picture of vast improvements at Camp East Montana.

In total, Amentum and its affiliated and acquired companies have accumulated 112 regulatory violations and paid more than $94 million in penalties since the year 2000, according to Violation Tracker.[88] This includes $56 million in nine instances of government contracting offenses, $32 million in 57 instances of employment-related offenses, $3.8 million in 42 safety related violations, including eight nuclear safety violations, and $2.4 million in five separate employment discrimination cases.[89]

Since the year 2000, Amentum Services Inc., and subsidiaries of its parent company, Amentum Holdings, Inc., have been cited and fined more than $500,000 for worker health and safety violations by the Occupational Safety and Health Administration (OSHA), that includes more than $125,000 over the past six years alone. Since 2020, Amentum and its subsidiaries have been cited for one dozen health and safety violations in nine separate incidents, including one fatality, according to OSHA records.[90] One 2023 incident involved the potential exposure of workers at the Central Intelligence Agency’s (CIA’s) headquarters in Virginia to toxic diphenylmethane diisocyanate vapors.[91] Another incident in 2024, involved a fatality at Fort Belvoir, in Virginia. [92]

These sorts of health and safety related incidents are particularly relevant to Amentum’s new contract to oversee the 5,000-bed immigration detention center at Camp East Montana that has already had at least one worker fatality and three detainee fatalities at the site in the first six months of its operation.

Legacy of Discriminatory Practices by Amentum Affiliated Companies

In 2019, the year before it became affiliated with Amentum, Washington River Protection Solutions (WRPS), the Department of Energy’s Office of Federal Contract Compliance Programs conducted an investigation and found that WRPS had discriminated against 151 Hispanic applicants who sought positions as health physics technician trainees with the company. The company did not admit liability, but in December 2022, agreed to pay $157,000 in back wages to the 151 Hispanic applicants in a settlement with the Department of Labor.[93]

In January 2020, AECOM Management Services, Inc. was rebranded Amentum. In September 2021, the company paid a $205,000 penalty for employment discrimination against 67 affected black applicants for “Aircraft Worker” positions in Virginia Beach, Virginia regarding their hiring process as part of a conciliation agreement with the Department of Labor’s Office of Federal Contract Compliance Programs.[94] On March 14, 2023, the company made its last distribution of funds to eligible applicants in this case.

Separately, in August 2020, AECOM Management Services, Inc. paid a $350,000 penalty as part of a conciliation agreement with the Department of Labor’s Office of Federal Contract Compliance Programs regarding its discriminatory hiring practices against 582 African-American and female applicants for Motor Equipment Metal Mechanic positions at the Red River Army Depot in Texarkana, Texas, between March 2013 and March 2015.[95]

On February 11, 2026, Bobby White, an African-American man, filed a civil rights complaint against Amentum Services Inc. in the U.S. District Court for the Northern District of Alabama, alleging that they engaged in unlawful, discriminatory and retaliatory employment practices.[96] White has worked for Amentum since November 2014 at the U.S. Army Depot in Anniston, Alabama, and worked at the facility for other contractors prior to that time.

False Claims Act & Related Violations

Although Amentum Services, Inc. has not been cited for False Claims Act or related violations itself, several of its related companies, that are subsidiaries of Amentum Holdings, Inc., have been cited for False Claims Act violations over the years, amounting to total fines or civil suits of more than $57 million.[97]

In April 2025, DynCorp International, LLC, acquired by Amentum in November 2020,[98] agreed to a $21 million Department of Justice (DOJ) settlement related to False Claims Act violations for knowingly billing the Department of State with inflated costs on a contract to train Iraqi police forces.[99] In a separate case in June 2025, Washington River Protection Solutions (WRPS), another Amentum subsidiary, agreed to pay $6.5 million to resolve allegations of fraud related to the company’s overcharging of labor hours involving millions of dollars on a Department of Energy contract.[100]

Table 1: Amentum Affiliated Companies’ False Claims Act & Related Violations[101]

Amentum Subsidiary or Affiliated Company	Primary Offense	Federal Agency	Year	Fine
DynCorp International LLC	False Claims Act and related offenses	DOJ Civil	2025	$21,000,000
Washington River Protection Solutions LLC	False Claims Act and related offenses	USAO/DOJ	2025	$6,500,000
DynCorp International LLC	Kickbacks & Bribery	USAO/DOJ	2020	$1,500,000
PAE Applied Technologies LLC	False Claims Act and related offenses	USAO/DOJ	2019	$4,200,000
Washington Closure Hanford LLC	False Claims Act and related offenses	USAO/DOJ	2018	$3,200,000
Washington River Protection Solutions LLC	False Claims Act and related offenses	DOJ Civil	2017	$5,275,000
Pacific Architechs and Engineers LLC	False Claims Act and related offenses	USAO/DOJ	2017	$5,000,000
PAE Government Service Inc. and RM Asia (HK) Limited	False Claims Act and related offenses	DOJ Civil	2015	$1,450,000
DynCorp International LLC	False Claims Act and related offenses	DOJ Civil	2011	$7,700,000
EG&G Technical Solutions, Inc.	False Claims Act and related offenses	USAO/DOJ	2009	$1,765,164
TOTAL				$57,590,164

TIES THAT BIND

Acquisition Logistics LLC and its senior officials do not appear to have any public ties to President Trump or his family and have not made any contributions to any of Trump’s political campaigns, based on a review of Federal Election Commission (FEC) data.

However, Nathan Albers, owner of Disaster Management Group (DMG) that is cited as one of the Acquisition Logistics subcontractors on the Camp East Montana project, has made substantial political donations to Republican political campaigns, including more than $150,000 in 2025 alone.[102] In addition, he and his wife have close ties to Trump’s family, according to public records. The Albers’ reportedly attended election night in 2024 at Mar-a-Lago and Nathan Albers once reportedly co-chaired a charity fundraiser at Trump National Golf Club with Eric and Lara Trump, according to reporting from ProPublica.[103] Albers also reportedly attended the “Crypto Ball” sponsored by supporters of Donald Trump in January 2025.[104] In early March 2026, Kimberly Albers also co-chaired a pet fundraiser at Mar-a-Largo with Lara Trump, the President’s daughter-in-law.[105]

Disaster management has been good for Nathan Albers. He appears to have profited handsomely from his various government contracts. In October 2024, it was reported that he purchased an 8,000 square foot waterfront mansion for $30 million on the Jupiter Inlet in Florida, about 24 miles north of Mar-a-Lago.[106] In addition, Albers’ personal connections to the Trump family raise questions about how his company, Disaster Management Group became involved with the DHS contract at Camp East Montana, particularly given the fact that DMG was fined $17.7 million in six separate incidents by the Department of Labor for wage and hour violations between 2021 and 2024.[107]

Since at least 2023, Kimberly Albers has been involved in a pet donation charity called Big Dog Ranch Rescue and their annual event at Mar-A-Lago. Kimberly and Nathan Albers, along with Eric Trump (President Trump’s son), and his wife Lara Trump posed for a photograph together at this event in 2023.[108]

In April 2024, Kimberly Albers also posted a photo on Instagram posing alongside Kimberly Guilfoyle, Donald Trump, Jr.’s former fiancée,[109] who was appointed by Donald Trump to be the U.S. Ambassador to Greece, and was confirmed by the U.S. Senate for that position in September 2025.[110]

From Friday, March 6^th to Sunday, March 8, 2026, Kim Albers co-chaired a “Wine, Women and Shoes” fundraising event for the Big Dog Rescue Ranch charity at Mar-A-Lago. Lara Trump served as the honorary chair of the event.[111]

It is unclear if Albers’ company, DMG, has any role in the new Camp East Montana contract with Amentum. Despite assertions by DHS that “no other vendor” was capable of fulfilling the contract except Amentum, questions remain about how and why it received the contract and why it was not opened up to a competitive bidding process.

There do not appear to be close political ties between Amentum and Donald Trump. However, the owner of one of the major companies that Amentum purchased in 2020, DynCorp International, has had very close ties to President Trump. In 2010, Cerberus Capital Management acquired DynCorp. for $1.5 billion.[112] Cerberus’ co-Chief Executive Officer (CEO), Stephen Feinberg, has been an active supporter of Donald Trump.[113] During the 2016 and 2020 Presidential elections Feinberg reportedly donated a reported $3.2 million to pro Trump PACs.[114] In addition, during Donald Trump’s run for the Presidency in 2016, Feinberg served on Trump’s Economic Advisory Council.[115] In May 2018, President Trump named Feinberg the Chair of the President’s Intelligence Advisory Board.[116] More recently, during his second term in office, President Trump nominated Feinberg to be the Deputy Secretary of Defense and he was sworn into that position in March 2025.[117] He is seen below seated next to Defense Secretary Pete Hegseth.

To be clear, Feinberg has not maintained any official positions with Amentum since they purchased DynCorp. Records also show that Amentum has not contributed to any of Donald Trump’s political campaigns. However, Amentum’s CEO, John Heller, personally met with Trump in September 2025 in the United Kingdom during Trump’s state visit to the U.K. During that visit Heller announced that Amentum would create 3,000 new jobs in the U.K.’s nuclear power industry and the company said in a press release and social media post on X, that they hoped Amentum could help “deliver on President Trump’s executive orders calling for a quadrupling of nuclear generating capacity by 2050.”[118] It is not known if Heller and Trump discussed the Camp East Montana facility during their meeting in the United Kingdom.

Conclusion

Camp East Mountain is a case study in the reckless cruelty of the Trump administration’s mass detention and deportation agenda. In service of a commitment to arrest and deport huge numbers of people, the administration is rushing to create a physical infrastructure sufficient to manage a surge of detainees. In doing so, it is cutting corners – and the horrific, and sometimes deadly, results are already evident.

The administration entered into a contract with Acquisition Logistics, a company with no experience operating at the scale of the Camp East Montana project, rushing forward in violation of normal contracting rules, and paving the way for avoidable human tragedy. Now it has replaced its first, failed contractor with a new, no-bid contract conferred on an enterprise that has compiled a sordid record of wrongdoing.

The detainee population at Camp East Montana is expected to eventually grow from an estimated 3,000 detainees today to 5,000 detainees when the center is at full capacity.[119] That will inevitably lead to more management and operational challenges and will likely lead to more problems, safety, health and security concerns regarding the detainee population, not less.

Unfortunately, Amentum’s past actions do not provide confidence that it will ensure that the people who are and will be detained at Camp East Montana – most of whom will not be criminals, contrary to administration claims, and many of whom may have legal right to be in the United States – receive decent and humane treatment they deserve.

Endnotes:

[1] Acquisition Logistics LLC, Contract Award Summary for ICE Detention Center, Ft. Bliss, Texas, Department of Defense (DOD), U.S. Army, USASPENDING.GOV (July 19, 2025), https://www.usaspending.gov/award/CONT_AWD_W9124J25FA075_9700_N0002325D0004_9700

[2] Kimmy Yam, “Japanese American groups blast use of Fort Bliss, former internment camp site, as ICE detention center,” NBC NEWS (August 20, 2025), https://www.aol.com/japanese-american-groups-blast-fort-194449232.html

[3] Acquisition Logistics LLC, Contract Award Summary for ICE Detention Center, Ft. Bliss, Texas, Department of Defense (DOD), U.S. Army, USASPENDING.GOV (July 19, 2025), https://www.usaspending.gov/award/CONT_AWD_W9124J25FA075_9700_N0002325D0004_9700

[4] Acquisition Logistics LLC, Indefinite Delivery / Indefinite Quantity (IDIQ) Contract, Department of Defense (DOD), U.S. Department of the Navy, USASPENDING.GOV (January 1, 2025), https://www.usaspending.gov/award/CONT_IDV_N0002325D0004_9700

[5] Amentum Services Inc., Camp East Montana Contract Award Summary, Department of Homeland Security (DHS), SAM.GOV (March 11, 2026), https://sam.gov/workspace/contract/opp/a8f590826172447b85036a8777b2cdd5/view

[6] Amentum Services Inc. search, Public Access To Court Electronic Records (PACER), https://pcl.uscourts.gov/

[7] Amentum Government Services Holdings LLC (now renamed Amentum Holdings Inc.), VIOLATION TRACKER, https://violationtracker.goodjobsfirst.org/?company_op=starts&company=amentum

[8] TEXAS SECRETARY OF STATE, https://www.sos.state.tx.us/corp/sosda/index.shtml

[9] “Competition in Contracting Act of 1984,” CONGRESS.GOV, https://www.congress.gov/bill/98th-congress/house-bill/5184

[10] Opinion and Order, Gemini Tech Services, LLC vs. The United States and Acquisition Logistics LLC, UNITED STATES COURT OF FEDERAL CLAIMS No. 25-1337C (issued under seal September 8, 2025 and reissued for publication on September 18, 2025), https://www.casemine.com/judgement/us/68ce63548edb569a8a375455

[11] Acquisition Logistics LLC search, Public Access To Court Electronic Records (PACER), https://pcl.uscourts.gov/

[12] Kristian Jaime, “Subcontractor employee death sparks OSHA investigation in Fort Bliss ICE facility,” EL PASO TIMES (August 22, 2025), https://www.elpasotimes.com/story/news/immigration/2025/08/22/osha-army-probe-fatal-incident-at-fort-bliss-immigration-facility/85782326007/

[13] Jesús Jank Curbelo, “The black hole of Camp East Montana: Three deaths in 44 days at the largest migrant detention center in the US,” EL PAIS (January 21, 2026), https://english.elpais.com/usa/2026-01-21/the-black-hole-of-camp-east-montana-three-deaths-in-44-days-at-the-largest-migrant-detention-center-in-the-us.html

[14] Ibid.

[15] Disaster Management Group LLC, VIOLATION TRACKER, https://violationtracker.goodjobsfirst.org/?company_op=starts&company=disaster+management

[16] Joseph Konig, “Immigration detention camp billed as the largest in U.S. history officially opens at Texas' Fort Bliss,” SPECTRUM NEWS (August 19, 2025), https://spectrumlocalnews.com/us/snplus/news/2025/08/19/fort-bliss-lone-star-lockup-texas-immigration-detention-military

[17] Base International Inc., FLORIDA DIVISION OF CORPORATIONS, https://search.sunbiz.org/Inquiry/CorporationSearch/SearchResultDetail?inquirytype=EntityName&directionType=Initial&searchNameOrder=BASEINTERNATIONAL%20F240000031220&aggregateId=forp-f24000003122-09b7373a-461b-44d8-9461-8bf5cf30c282&searchTerm=base%20international&listNameOrder=BASEINTERNATIONAL%20F240000031220

[18] Avi Asher-Schapiro and Jeff Ernsthausen, “His Former Company Got Caught Employing Undocumented Workers. Now He’s Profiting Off an Immigrant Detention Camp,” PROPUBLICA (July 25, 2025), https://www.propublica.org/article/nathan-albers-fort-bliss-immigration

[19] “Big Dog Ranch Rescue Raises Record Breaking $5.5 Million At Fundraiser,” TOWN-CRIER (March 20, 2026), https://gotowncrier.com/2026/03/big-dog-ranch-rescue-raises-record-breaking-5-5-million-at-fundraiser/

[20] “Treasure Coast Corporation and Corporate Officers Charged with Conspiring to Conceal and Harbor Aliens for the Purpose of Commercial Advantage,” U.S. Attorney’s Office, Southern District of Florida, DEPARTMENT OF JUSTICE (July 12, 2019), https://www.justice.gov/usao-sdfl/pr/treasure-coast-corporation-and-corporate-officers-charged-conspiring-conceal-and-harbor

[21] “Treasure Coast Corporation and Corporate Officers Sentenced Federally for Conspiring to Conceal and Harbor Aliens for the Purpose of Commercial Advantage or Private Financial Gain,” U.S. Attorney’s Office, Southern District of Florida, DEPARTMENT OF JUSTICE (December 20, 2019), https://www.justice.gov/usao-sdfl/pr/treasure-coast-corporation-and-corporate-officers-sentenced-federally-conspiring

[22] Peter Johansson, “How a $1.2 Billion Army Award to a Small Contractor Created a Fort Bliss Detention Controversy, DEFENSE-AEROSPACE (September 21, 2025), https://www.defense-aerospace.com/how-a-1-2-billion-army-award-to-a-small-contractor-created-a-fort-bliss-detention-controversy/

[23] Acquisition Logistics LLC, Contract Award Summary for ICE Detention Center, Ft. Bliss, Texas, Department of Defense (DOD), U.S. Army, USASPENDING.GOV (July 19, 2025), https://www.usaspending.gov/award/CONT_AWD_W9124J25FA075_9700_N0002325D0004_9700

[24] Acquisition Logistics LLC, Contract Award Summary for ICE Detention Center, Transfer to DHS/ICE, Ft. Bliss, Texas, Department of Defense (DOD), U.S. Army, USASPENDING.GOV (November 14, 2025),  https://www.usaspending.gov/award/CONT_AWD_70CDCR26FR0000001_7012_N0002325D0004_9700

[25] Acquisition Logistics LLC, Indefinite Delivery / Indefinite Quantity (IDIQ) Contract, Department of Defense (DOD), U.S. Department of the Navy, USASPENDING.GOV (January 1, 2025), https://www.usaspending.gov/award/CONT_IDV_N0002325D0004_9700

[26] Acquisition Logistics LLC, VIRGINIA STATE CORPORATION COMMISSION, https://cis.scc.virginia.gov/EntitySearch/BusinessInformation?businessId=518220&source=FromEntityResult&isSeries%20=%20false.

[27] Ibid. Kenneth Alan Wagner was born on January 14, 1948, in Fort Lewis, Washington. He comes from a military family. His father, Dale Gordon Wagner, was a Chief Master Sergeant in the U.S. Air Force, who served in World War II, Korea, and Vietnam. His father died in 2016 at the age of 96 years old. Wagner’s mother, Emma Josefa Rodriguez Wagner was born in Mayaguez, Puerto Rico in 1916 and died at the age of 86 in 2002 in Florida. Wagner’s parents appear to have met in Puerto Rico when Dale Wagner was stationed there during World War II, and they were married in November 1945 in Mayaguez, Puerto Rico, according to Ancestry.com records.

[28] Acquisition Logistics, ZOOMINFO, https://www.zoominfo.com/c/the-acquisition-logistics-co/355452231

[29] Acquisition Logistics, LLC, ROCKETREACH, https://rocketreach.co/acquisition-logistics-llc-management_b40c4f37ffc1eb8e

[30] Acquisition Logistics Support Group, LLC, Automatically Canceled, Registration Fee, STATE CORPORATION COMMISSION, COMMONWEALTH OF VIRGINIA, https://cis.scc.virginia.gov/EntitySearch/BusinessFilings

[31] Michael Biesecker and Joshua Goodman, “Mystery surrounds $1.2 billion Army contract for huge detention camp in Texas desert,” ASSOCIATED PRESS (August 28, 2025), https://www.nbcdfw.com/news/national-international/mystery-army-contract-detention-camp-texas-desert/3911185/

[32] Opinion and Order, Gemini Tech Services, LLC v. The United States and Acquisition Logistics LLC, UNITED STATES COURT OF FEDERAL CLAIMS, (filed under seal on September 8, 2025, reissued for publication on September 18, 2025), https://dockets.justia.com/docket/federal-claims/cofce/1:2025cv01337/52683

[33] Acquisition Logistics LLC, Contract Award Summary for ICE Detention Center, Transfer to DHS/ICE, Ft. Bliss, Texas, Department of Defense (DOD), U.S. Army, USASPENDING.GOV (November 14, 2025),  https://www.usaspending.gov/award/CONT_AWD_70CDCR26FR0000001_7012_N0002325D0004_9700

[34] Enemy Alien Internment in Texas during World War II, TEXAS HISTORICAL COMMISSION (August 2020), https://www.thc.texas.gov/public/upload/publications/Alien_Enemy_Brochure_08_20.pdf

[35] Ibid.

[36] Omar Ornelas, “Photos of Camp East Montana, controversial ICE facility in El Paso,” EL PASO TIMES, (October 13, 2025) https://www.elpasotimes.com/picture-gallery/news/immigration/2025/10/13/camp-east-montana-photo-gallery-of-ice-immigration-detention-facility-fort-bliss-el-paso-texas/86616916007/

[37] Gemini Tech Services, LLC (W911SE-2372), Bid Protest, GOVERNMENT ACCOUNTABILITY OFFICE (GAO) (July 28, 2025), https://www.gao.gov/docket/b-423775.1#:~:text=Posted%20on%20Sep%2009%2C%202025,Culliton

[38] Opinion and Order, Gemini Tech Services, LLC v. The United States and Acquisition Logistics LLC, UNITED STATES COURT OF FEDERAL CLAIMS, (filed under seal on September 8, 2025, reissued for publication on September 18, 2025), https://dockets.justia.com/docket/federal-claims/cofce/1:2025cv01337/52683

[39] Ibid.

[40] Ibid.

[41] Ibid.

[42] Ibid.

[43] Ibid.

[44] Presidential Executive Order 14159, Protecting the American People Against Invasion, THE WHITE HOUSE (January 20, 2025), https://www.whitehouse.gov/presidential-actions/2025/01/protecting-the-american-people-against-invasion/

[45] Opinion and Order, Gemini Tech Services, LLC v. The United States and Acquisition Logistics LLC, UNITED STATES COURT OF FEDERAL CLAIMS, (filed under seal on September 8, 2025, reissued for publication on September 18, 2025), https://dockets.justia.com/docket/federal-claims/cofce/1:2025cv01337/52683

[46] Ibid.

[47] Ibid.

[48] Ibid.

[49] Ibid.

[50] Acquisition Logistics LLC, Contract Award Summary for ICE Detention Center, Transfer to DHS/ICE, Ft. Bliss, Texas, Department of Defense (DOD), U.S. Army, USASPENDING.GOV (November 14, 2025),  https://www.usaspending.gov/award/CONT_AWD_70CDCR26FR0000001_7012_N0002325D0004_9700

[51] Natalie Venegas, “Amentum Services named new contractor for Camp East Montana detention center.” KFOX14 News (March 16, 2026), https://kfoxtv.com/news/local/amentum-services-named-new-contractor-for-el-pasos-camp-east-montana-detention-center

[52] “Mystery surrounds $1.2 billion Army contract to build huge detention tent camp in Texas desert,” PBS NEWS (August 28, 2026), https://www.pbs.org/newshour/politics/mystery-surrounds-1-2-billion-army-contract-to-build-huge-detention-tent-camp-in-texas-desert

[53] Public Citizen conversation with Texas Secretary of State official on March 27, 2026.

[54] “Foreign or Out-of-State Entities,” TEXAS SECRETARY OF STATE’S OFFICE, accessed March 20, 2026, https://www.sos.state.tx.us/corp/foreign_outofstate.shtml

[55] Avi Asher-Schapiro and Jeff Ernsthausen, “His Former Company Got Caught Employing Undocumented Workers. Now He’s Profiting Off an Immigrant Detention Camp,” PROPUBLICA (July 25, 2025), https://www.propublica.org/article/nathan-albers-fort-bliss-immigration

[56] “Nearly $16M in wages, benefits recovered for more than 2,800 workers denied full pay by 62 subcontractors on federal project at New Jersey military base,” DEPARTMENT OF LABOR, Wage and Hour Division (January 29, 2024), https://www.dol.gov/newsroom/releases/whd/whd20240129

[57] Disaster Management Group LLC, VIOLATION TRACKER, https://violationtracker.goodjobsfirst.org/?company_op=starts&company=disaster+management

[58] Articles of Organization for Disaster Management Group, LLC, FLORIDA DIVISION OF CORPORATIONS (February 6, 2006) https://search.sunbiz.org/Inquiry/CorporationSearch/ConvertTiffToPDF?storagePath=COR%5C2006%5C0213%5C90473969.Tif&documentNumber=L06000013077

[59] Premier Party Rentals, Inc. 2007 For Profit Corporation Annual Report, FLORIDA DIVISON OF CORPORATIONS (January 9, 2007), https://search.sunbiz.org/Inquiry/CorporationSearch/ConvertTiffToPDF?storagePath=COR%5C2007%5C0109%5C20797192.tif&documentNumber=P96000032997

[60] Articles of Amendment, Name Change from Premier Party Rentals, Inc. to TentLogix, Inc. FLORIDA DIVISION OF CORPORATIONS (July 30, 2010), https://search.sunbiz.org/Inquiry/CorporationSearch/ConvertTiffToPDF?storagePath=COR%5C2010%5C0805%5C00173278.Tif&documentNumber=P96000032997

[61] “Treasure Coast Corporation and Corporate Officers Charged with Conspiring to Conceal and Harbor Aliens for the Purpose of Commercial Advantage,” U.S. Attorney’s Office, Southern District of Florida, DEPARTMENT OF JUSTICE (July 12, 2019), https://www.justice.gov/usao-sdfl/pr/treasure-coast-corporation-and-corporate-officers-charged-conspiring-conceal-and-harbor

[62] “Treasure Coast Corporation and Corporate Officers Sentenced Federally for Conspiring to Conceal and Harbor Aliens for the Purpose of Commercial Advantage or Private Financial Gain,” U.S. Attorney’s Office, Southern District of Florida, U.S. DEPARTMENT OF JUSTICE (December 20, 2019), https://www.justice.gov/usao-sdfl/pr/treasure-coast-corporation-and-corporate-officers-sentenced-federally-conspiring

[63] “Treasure Coast Corporation and Corporate Officers Sentenced Federally for Conspiring to Conceal and Harbor Aliens for the Purpose of Commercial Advantage or Private Financial Gain,” U.S. Attorney’s Office, Southern District of Florida, DEPARTMENT OF JUSTICE (December 20, 2019), https://www.justice.gov/usao-sdfl/pr/treasure-coast-corporation-and-corporate-officers-sentenced-federally-conspiring

[64] Christopher Bokum, “TentLogix Files for Chapter 11 Bankruptcy Following 2019 Indictment,” LEVELSET.COM (July 30, 2021), https://www.levelset.com/news/tentlogix-chapter-11-bankruptcy/

[65] Acquisition Logistics LLC, Contract Award Summary for ICE Detention Center, Ft. Bliss, Texas, Department of Defense (DOD), U.S. Army, USASPENDING.GOV (July 19, 2025), https://www.usaspending.gov/award/CONT_AWD_W9124J25FA075_9700_N0002325D0004_9700

[66] Acquisition Logistics LLC, Inspection: 1859269.015, Accident: 2323120, OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION (OSHA) (July 21, 2025), https://www.osha.gov/ords/imis/establishment.inspection_detail?id=1859269.015

[67] JMJ Production Services, LLC, Inspection: 11840556.015, OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION (OSHA) (July 21, 2025), https://www.osha.gov/ords/imis/establishment.inspection_detail?id=1840556.015

[68] Fulfillment Personnel Services, LLC, Inspection: 1840555.015, OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION (OSHA) (July 21, 2025), https://www.osha.gov/ords/imis/establishment.inspection_detail?id=1840555.015

[69] Base International Inc., Inspection: 1838708.015, OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION (OSHA) (July 21, 2025), https://www.osha.gov/ords/imis/establishment.inspection_detail?id=1838708.015

[70] Base International Inc., FLORIDA DIVISION OF CORPORATIONS, https://search.sunbiz.org/Inquiry/CorporationSearch/SearchResultDetail?inquirytype=EntityName&directionType=Initial&searchNameOrder=BASEINTERNATIONAL%20F240000031220&aggregateId=forp-f24000003122-09b7373a-461b-44d8-9461-8bf5cf30c282&searchTerm=base%20international&listNameOrder=BASEINTERNATIONAL%20F240000031220

[71] Joseph Konig, “Immigration detention camp billed as the largest in U.S. history officially opens at Texas' Fort Bliss,” SPECTRUM NEWS (August 19, 2025), https://spectrumlocalnews.com/us/snplus/news/2025/08/19/fort-bliss-lone-star-lockup-texas-immigration-detention-military

[72] Base International Inc., Inspection: 1838708.015, OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION (OSHA) (July 21, 2025), https://www.osha.gov/ords/imis/establishment.inspection_detail?id=1838708.015

[73] Hector Horacio Gonzalez (March 27, 1987-July 21, 2025), Obituary, LEGACY.COM, https://www.legacy.com/us/obituaries/name/hector-gonzalez-memorial?id=58984806

[74] JMJ Production Services, LLC, Inspection: 11840556.015, OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION (OSHA) (July 21, 2025), https://www.osha.gov/ords/imis/establishment.inspection_detail?id=1840556.015

[75] Fulfillment Personnel Services, LLC, Inspection: 1840555.015, OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION (OSHA) (July 21, 2025), https://www.osha.gov/ords/imis/establishment.inspection_detail?id=1840555.015

[76] Acquisition Logistics LLC, Inspection: 1859269.015, Accident: 2323120, OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION (OSHA) (July 21, 2025), https://www.osha.gov/ords/imis/establishment.inspection_detail?id=1859269.015

[77] “60 violations in 50 days: Inside ICE’s giant tent facility at Ft. Bliss,” THE WASHINGTON POST (September 16, 2025), https://www.washingtonpost.com/business/2025/09/16/ice-detention-center-immigration-violations/

[78] Morgan Lee, Ryan J. Foley and Michael Biesecker, “‘Worse than a prison': 911 calls, interviews reveal problems at ICE’s largest detention camp,” ASSOCIATED PRESS (March 6, 2026), https://apnews.com/article/ice-detention-camp-conditions-911-calls-738c63a2b96a90c2f85a668ec2fd3b5b

[79] Jesús Jank Curbelo, “The black hole of Camp East Montana: Three deaths in 44 days at the largest migrant detention center in the US,” EL PAIS (January 21, 2026), https://english.elpais.com/usa/2026-01-21/the-black-hole-of-camp-east-montana-three-deaths-in-44-days-at-the-largest-migrant-detention-center-in-the-us.html

[80] Colleen DeGuzman, “Immigrant’s death in ICE custody ruled homicide by El Paso medical examiner,” THE TEXAS TRIBUNE (January 21, 2026), https://www.texastribune.org/2026/01/21/texas-el-paso-immigrant-death-ice-custody-homicide/

[81] Ibid.

[82] Laura Strickler and Daniel Arkin, “Third immigrant detainee at facility in El Paso has died, ICE says,” NBC NEWS (January 19, 2026), https://www.nbcnews.com/news/us-news/third-immigrant-detainee-facility-el-paso-died-ice-says-rcna254783

[83] Amentum: About Us, AMENTUM.COM, https://www.amentum.com/

[84] “Amentum Completes Transformational Combination with Jacobs’ Critical Mission Solutions and Cyber and Intelligence Units,” Press Release, AMENTUM.COM, (September 27, 2024), https://www.amentum.com/news/amentum-completes-transformational-combination-with-jacobs-critical-mission-solutions-and-cyber-and-intelligence-units/

[85] Amentum Services Inc., Camp East Montana Contract Award Summary, Department of Homeland Security (DHS), SAM.GOV (March 11, 2026), https://sam.gov/workspace/contract/opp/a8f590826172447b85036a8777b2cdd5/view

[86] Ibid.

[87] Ibid.

[88] Amentum Government Services Holdings LLC, Violation Tracker, https://violationtracker.goodjobsfirst.org/parent/amentum-government-services-holdings-llc

[89] Ibid.

[90] Ibid.

[91] Amentum, Inspection: 1654142.015, Incident Occurrence, February 16, 2023, OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION (OSHA) (March 1, 2023), https://www.osha.gov/ords/imis/establishment.inspection_detail?id=1654142.015

[92] Amentum Services, Inc., Inspection: 1767588.015, Incident Occurrence, August 6, 2024, OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION (OSHA) (August 8, 2024), https://www.osha.gov/ords/imis/establishment.inspection_detail?id=1767588.015

[93] “US Department of Labor reaches agreement with environmental cleanup provider to resolve alleged hiring discrimination at Richland’s Hanford Site,” Press Release, Office of Federal Contract Compliance Program, U.S. DEPARTMENT OF LABOR (December 8, 2022), https://www.dol.gov/newsroom/releases/ofccp/ofccp20221208

[94] See: AECOM Management Services, Inc. (Parent Company: Amentum Government Services Holdings LLC), VIOLATION TRACKER (September 30, 2021), https://violationtracker.goodjobsfirst.org/violation-tracker/va-aecom-management-services-inc and Conciliation Agreement Between the Department of Labor Office of Federal Contract Compliance Programs and AECOM Management Services, Inc., DEPARTMENT OF LABOR (Undated), https://www.dol.gov/sites/dolgov/files/OFCCP/foia/files/2021-09-30AECOM301560MACA_Redacted.pdf

[95] See: AECOM Management Services, Inc. (Parent Company: Amentum Government Services Holdings LLC), VIOLATION TRACKER (August 10, 2020), https://violationtracker.goodjobsfirst.org/violation-tracker/tx-aecom-management-services-inc and Conciliation Agreement Between the U.S. Department of Labor Office of Federal Contract Compliance Programs and AECOM Management Services, Inc., Red River Army Depot, Texarkana, Texas, U.S. DEPARTMENT OF LABOR (August 10, 2020), https://www.dol.gov/sites/dolgov/files/ofccp/foia/files/2020-08-10AECOM_CA_SW_Redacted.pdf

[96] Bobby White vs. Amentum Services, Inc., Case 5:26-cv-00221-HDM, UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ALABAMA NORTHEASTERN DIVISION, (February 11, 2026).

[97] Amentum, VIOLATION TRACKER, https://violationtracker.goodjobsfirst.org/?company_op=starts&company=amentum

[98] “Amentum Closes DynCorp Acquisition,” Press Release, AMENTUM.COM (November 23, 2020), https://www.amentum.com/news/amentum-closes-dyncorp-acquisition/

[99] “DynCorp Agrees to Pay $21 Million to Resolve False Claims Act Lawsuit Alleging Inflated Costs on State Department,” U.S. Attorney’s Office, District of Columbia, U.S. DEPARTMENT OF JUSTICE (April 9, 2025), https://www.justice.gov/usao-dc/pr/dyncorp-agrees-pay-21-million-resolve-false-claims-act-lawsuit-alleging-inflated-costs

[100] “Hanford Contractor, Washington River Protection Solutions (WRPS), Agrees to Pay $6.5 Million to Resolve Allegations of Fraud,” U.S. Attorney’s Office, Eastern District of Washington, U.S. DEPARTMENT OF JUSTICE (June 24, 2025), https://www.justice.gov/usao-edwa/pr/hanford-contractor-washington-river-protection-solutions-wrps-agrees-pay-65-million

[101] Amentum, VIOLATION TRACKER, https://violationtracker.goodjobsfirst.org/?company_op=starts&company=amentum

[102] Avi Asher-Schapiro and Jeff Ernsthausen, “His Former Company Got Caught Employing Undocumented Workers. Now He’s Profiting Off an Immigrant Detention Camp,” PROPUBLICA (July 25, 2025), https://www.propublica.org/article/nathan-albers-fort-bliss-immigration

[103] Avi Asher-Schapiro and Jeff Ernsthausen, “His Former Company Got Caught Employing Undocumented Workers. Now He’s Profiting Off an Immigrant Detention Camp,” PROPUBLICA (July 25, 2025), https://www.propublica.org/article/nathan-albers-fort-bliss-immigration

[104] Ibid.

[105] “Big Dog Ranch Rescue Raises Record Breaking $5.5 Million At Fundraiser,” TOWN-CRIER (March 20, 2026), https://gotowncrier.com/2026/03/big-dog-ranch-rescue-raises-record-breaking-5-5-million-at-fundraiser/

[106] Kate Hinsche, “Disaster response mogul buys Jupiter Inlet Colony’s most expensive house for record $30M,” THE REAL DEAL (October 31, 2024), https://therealdeal.com/miami/2024/10/31/jupiter-inlet-colony-mansion-sells-for-record-30m/

[107] Disaster Management Group LLC, VIOLATION TRACKER, https://violationtracker.goodjobsfirst.org/?company_op=starts&company=disaster+management

[108] Big Dog Ranch Rescue, FACEBOOK post (December 13, 2023), https://www.facebook.com/photo/?fbid=750889880413783&set=pcb.750890327080405

[109] Brandon Bombay, “Kimberly Guilfoyle’s Closest Gal Pals at Mar-a-Lago Scream Desperate Housewives,” NICKI SWIFT.COM (December 22, 2024), https://www.nickiswift.com/1740178/kimberly-guilfoyle-pals-mar-a-lago-scream-desperate-housewives/

[110] “U.S. Senate Confirms Kimberly Guilfoyle as U.S. Ambassador to the Hellenic Republic,”
U.S. EMBASSY & CONSULATE IN GREECE (September 19, 2025), https://gr.usembassy.gov/press-release-u-s-senate-confirms-kimberly-guilfoyle-as-u-s-ambassador-to-the-hellenic-republic/

[111] Big Dog Ranch Rescue, WINE, WOMENT & SHOES, https://www.winewomenandshoes.com/event/bdrr/

[112] “Cerberus to Buy DynCorp for $1.5 Billion,” Dealbook, THE NEW YORK TIMES (April 12, 2010), https://archive.nytimes.com/dealbook.nytimes.com/2010/04/12/cerberus-to-buy-dyncorp-for-1-5-billion/

[113] Oligarchs and the Trump Admin: Stephen Feinberg,” REVOLVING DOOR PROJECT (April 8, 2025), https://therevolvingdoorproject.org/billionaires-and-the-trump-admin-stephen-feinberg/

[114]Matthew Cunningham-Cook, “Major Trump Donor Owned Security Firm That Trained Khashoggi Killers,” THE INTERCEPT (June 24, 2021), https://theintercept.com/2021/06/24/khashoggi-trump-donor-saudi-arabia-tier-1/

[115] Catherine Macaulay, “Who’s Who in Defense: Stephen Feinberg, Deputy Secretary of Defense (DSD),” BREAKING DEFENSE (April 1, 2025), https://breakingdefense.com/2025/04/whos-who-in-defense-stephen-feinberg-deputy-secretary-of-defense-dsd/

[116] Ibid.

[117] Ibid.

[118] “Amentum to create 3,000 jobs as U.K. nuclear renaissance and defence spending boost growth,” AMENTUM.COM (September 18, 2025), https://www.amentum.com/news/amentum-to-create-3000-jobs-as-u-k-nuclear-renaissance-and-defence-spending-boost-growth/

[119] Aaron Reichlin-Melnick, “ICE’s Warehouse Purchases Herald New Model for Immigration Detention,” AMERICAN IMMIGRATION COUNCIL (February 24, 2026), https://www.americanimmigrationcouncil.org/blog/ice-buys-warehouses-immigration-detention/?utm_source=chatgpt.com

 

April 12, 2026

Affected With A Public Interest: Restoring Accountability, Reliability and Affordability For Utility Service

By Tyson Slocum

Here is a link to a presentation made to William & Mary law students on March 30 covering victories Public Citizen has achieved at the Federal Energy Regulatory Commission, and a list of reforms to address energy affordability: TysonWM

April 10, 2026

Letter Urging California Office of Administrative Law Not to Approve Emissions Disclosure Rule for Administrative Deficiencies

April 8, 2026

Attn: Kenneth J. Pogue, Director
California Office of Administrative Law
300 Capitol Mall, Suite 1250
Sacramento, CA 95814-4339

Dear Mr. Pogue,

Public Citizen is among the nonprofit organizations that have spent years promoting the passage and implementation of the California Greenhouse Gas Reporting and Climate Related Risk Disclosure laws, now codified at California Health & Safety Code §§ 38532 (SB 253) and 38533 (SB 261). We write to you now regarding the Initial Regulation to establish fees, timelines, and definitions for implementing the laws, also known as the “fee regulation,” which the California Air Resources Board (CARB) adopted at a public hearing on February 26. As the final rule package – including the rule, responses to public comment, and the final statement of reasons – now makes its way to the Office of Administrative Law, we ask you to address a number of procedural and substantive concerns before publication. 

First, CARB introduced a wholly novel rationale for exempting insurance companies from SB 253 at the public hearing on February 26, where it voted to approve the regulation. In its Initial Statement of Reasons published in December 2025, CARB staff suggested that insurers were being exempted from the rule to promote “continuity” with the rule implementing the Climate-Related Financial Risk Act (SB 261). Then at the public hearing, CARB offered a new explanation for the exemption—avoiding duplicative effort for reporting entities—but failed to provide an opportunity for public comment on that justification before finalizing the exemption. Government Code § 11346.8(a) states that if a public hearing is held, the agency “shall consider all relevant matter presented to it before adopting, amending, or repealing any regulation.” CARB was unable to consider “all relevant matter” in this case because the public was in the dark about the new rationale before the hearing and adoption of the rule that same day.

Further, OAL’s own guidance, consistent with the Administrative Procedures Act, provides that: 

“A rulemaking agency must specifically identify any material the agency is relying upon for the proposed rulemaking in the initial statement of reasons. If during a rulemaking proceeding an agency decides to rely on material that the agency did not identify in the initial statement of reasons, the agency must make the document available for comment for 15 days. This notice and comment process is similar to the 15-day notice for substantial, sufficiently related changes to the regulation text.”

It is unclear whether CARB relied on particular “material” or a “document” in presenting its novel duplication justification for the insurance exemption at the February 26 public hearing. It is clear, however, that the public did not have opportunity to review and comment on that rationale, violating the requirements and flouting the purpose of notice and comment rulemaking. This is especially true in light of the significant public interest in the exemption and the amount of controversy it has engendered.

Second, the Air Resources Board impermissibly excluded the insurance sector from the Fee Regulation, contrary to law. As we have stated previously, the exemption is inconsistent with statute, diminishes the benefits of the program, and creates a special carve out for an industry that is tightly linked to the state’s climate-related challenges. The exemption for insurers could even make the rule vulnerable in court: The California legislature originally considered versions of both disclosure bills, SB 253 and SB 261, that did not exempt insurance companies. However, an exemption was ultimately added to SB 261 in recognition that the climate financial risk disclosure required by SB 261 significantly overlapped with the financial risk disclosure standard adopted by the National Association of Insurance Commissioners. In contrast, the emissions disclosure bill SB 253 was signed into law without an exemption for insurance companies. The Board lacks authority to carve out an exemption that does not exist in the statute and that the legislature considered and rejected. At CARB’s February 26 hearing, SB 253 author Senator Scott Wiener testified that his and the Legislature’s intent was not to exclude insurers from SB 261 emissions reporting, that an exemption was not included in SB 253, and that “the law of California” is that the insurance industry must disclose emissions.  

Third, CARB’s justification of avoiding duplicative effort for reporting entities is itself a misreading of the statute. CARB argues that requiring insurers to report their emissions under this rule would be duplicative with reporting already required by the California Department of Insurance (CDI) via the NAIC Climate Risk Disclosure Surveys. CARB further grounds this interpretation in the text of the statute. CA Health & Safety Code 38532(c)(2)(D)(i) requires CARB to adopt regulations for SB 253 that ensure: 

“That the emissions reporting is structured in a way that minimizes duplication of effort and allows a reporting entity to submit … reports prepared to meet other national and international reporting requirements, including any reports required by the federal government, as long as those reports satisfy all of the requirements of this section.”

CARB is misreading the duplication language in the statute, which allows a reporting entity to file with CARB the emissions disclosures they are making to other national or international agencies, so long as the emissions disclosures to other agencies meet the standards of SB 253. It does not authorize CARB to exempt a whole industry from reporting to CARB just because they may be reporting to another agency. The legislative history of the climate risk disclosure laws further make clear that the amendments introduced and codified by SB 219 were intended to reduce administrative burden on companies in two key ways:

• Parent-Level Reporting: SB 219 clarified that subsidiaries need not prepare separate reports if the parent company includes all relevant emissions data in a consolidated filing. (2)(a)(iii)
• Flexible Reporting: SB 219 made clear that covered companies could satisfy reporting requirements by using existing reports submitted to other jurisdictions, so long as those reports meet all necessary criteria.

Moreover, the reports CARB is referring to in this instance, namely the NAIC surveys filed by insurers with the Department of Insurance, categorically do not “satisfy all of the requirements” of the emissions disclosure law, which mandates that all covered entities disclose their Scope 1, 2, and 3 emissions. In contrast, the NAIC climate risk disclosure survey administered by CDI simply encourages insurers to “disclose Scope 1, Scope 2, and if appropriate, Scope 3 greenhouse gas emissions.” There is no statute or regulation requiring insurers to report greenhouse gas emissions to CDI, nor does CDI have any authority to enforce fines or penalties against insurers who decline to disclose emissions.  

There is also no duplication in fact. Public Citizen recently published an analysis confirming that the insurers reports to CDI do not satisfy the requirements of the emissions disclosure law to report Scope 1, 2, and 3 emissions. An analysis of the 2024 Climate Risk Disclosure Surveys submitted by the largest 20 property and casualty (P&C) insurers operating in California – roughly 70 percent of the market – reveals significant gaps in insurer emissions reporting to CDI. In fact, only 10 percent of the largest insurers in California make meaningful emissions disclosures to CDI inclusive of Scope 1, 2, and 3 emissions.

The lack of Scope 3 reporting is especially glaring: SB 253 was a landmark law precisely because it mandated disclosure of this complex and essential class of indirect emissions. Scope 3 emissions, including emissions from underwriting and investing in climate-intensive industries, comprise more than 95 percent of insurer emissions. For example, Allstate, which included financed emissions and claims-handling emissions, but excluded underwriting emissions in their reporting, found that their Scope 3 emissions made up 99% of the firm’s overall emissions contribution. With the inclusion of underwriting emissions, Scope 3 emissions would make up an even greater share of their total emissions. It follows that the reporting to CDI is insufficient to meet the requirements of the emissions disclosure law and there is no duplication in law or in fact.

For the reasons stated above, the Office of Administrative Law should return the rule to CARB with instructions to eliminate the insurance exemption under SB 253, adding insurers back to the scope of covered entities that must comply with emissions reporting requirements, consistent with the law. 

Thank you for your prompt consideration of this matter. Please do not hesitate to reach out to us with any questions or concerns.

Sincerely,

Clara Vondrich
Public Citizen
cvondrich@citizen.org

 

April 2, 2026

Trump’s Updated “Special Book”: More Attacks on Digital, Climate, and Health Policies

By Melinda St. Louis, Director at Public Citizen’s Global Trade Watch

First published on Common Dreams

One year ago today, Trump waved around the annual National Trade Estimates (NTE) Report when he announced his reciprocal tariffs, calling it a “special book” listing other countries’ purported “non-tariff trade barriers.” Using the threat of tariffs (now deemed illegal by the Supreme Court), President Trump has bullied countries into signing up to “reciprocal trade agreements” that target many of the policies included in the report. 

Earlier this week, the Office of the United States Trade Representative (USTR) released the updated 2026 version of this “special book,” and we can now see that this year’s NTE report continues and expands its targeting of critical public interest regulations related to safety in the digital economy, climate policy, environmental protection, public health, and more. 

Consumer advocates have long criticized the annual NTE because administrations of both parties have used it to parrot the demands of behemoth corporate interests, without sufficient regard to the public interest. After the Biden administration took positive steps, recognizing that public interest regulations should not necessarily be listed as “trade barriers,” the Trump administration reverted to regurgitating the hit list of Big Tech, Big Pharma, Big Ag, and other billionaire interests — and is now doubling down, attacking even more public interest laws around the world. 

Big Tech Accountability:

Given the proximity of Big Tech companies to the Trump administration, it was only to be expected that the NTE report would build on the previous year’s attacks on global digital policies. Unfortunately, this year’s report once again labels other countries’ digital ecosystem policies as “trade barriers,” simply because Big Tech companies find them objectionable.

The digital ecosystem regulations being targeted by the Trump administration include:

• Data protection, privacy, and data governance laws: This year’s report identifies 34 jurisdictions with laws that regulate cross-border data flows, compared to 27 in the 2025 NTE Report. This includes several data protection and privacy laws, including those in Brazil, Canada, the European Union (EU), Kenya, Nigeria, India, Turkiye, and Vietnam. These laws all aim to ensure that companies cannot evade local privacy and data protection norms simply by transferring data to jurisdictions with low privacy standards. The NTE report also targets several data governance measures that seek to regulate cross-border transfers of public sector data, sensitive information (such as health and financial data), and geospatial data. This includes laws in Bolivia, Ecuador, India, Korea, and South Africa.
• Anti-monopoly and revenue-sharing laws:  Several jurisdictions are attempting to create more competitive digital ecosystems by implementing digital sector-related competition regulation. Many of these are targeted in the NTE Report, which lists nine jurisdictions’ digital competition laws as trade barriers. This includes laws enacted in the EU, Japan, Turkiye, and the UK, and proposed regulations in Australia, Korea, Brazil, South Africa, and Vietnam. 

In addition, the report also targets various revenue-sharing regulations implemented by a number of jurisdictions. These regulations typically seek to force Big Tech platforms to support local industries that they cannibalize — such as traditional news producers — or to ensure that Big Tech platforms contribute to local content development. The report lists six jurisdictions with such laws — Australia, Korea, Canada, and the EU, which already have some form of regulation in place, as well as proposed regulations in New Zealand and South Africa. 

This is a significant increase from last year’s report, which listed a total of six jurisdictions’ digital competition-related or revenue-sharing laws.

• Digital services and other taxes: The Trump administration has consistently sought to prevent other countries from taxing U.S.-based Big Tech companies. Many countries are unable to appropriately levy income tax on Big Tech companies as these companies do not have a physical presence within their borders. Instead, they use Digital Services Taxes (DSTs) to ensure that these companies pay some tax within their jurisdictions. Similar to last year, the report identifies eight jurisdictions that have DSTs or equivalent taxes in place: Canada, Colombia, the EU, Kenya, Nigeria, Pakistan, Turkiye, and the UK.
• AI regulations: With AI quickly becoming embedded into nearly every aspect of our lives, some jurisdictions are seeking to regulate the development and deployment of AI systems to mitigate potential harms. This year’s report lists the EU’s AI Act as a trade barrier (similar to last year), but also includes another five jurisdictions’ AI-related policies as trade barriers, largely to oppose attempts at developing local AI ecosystems. For instance, the report targets Japan’s subsidies for building out domestic AI capacities and sovereign AI infrastructure. Similarly, domestic procurement norms in Korea and Ecuador have also been criticized. 

Climate/Environmental Protection:

While the urgency of climate change demands bold action at all levels, this year’s report unfortunately doubles down on the Trump administration’s hostility toward efforts to hasten a clean energy transition at home and globally. Instead of incorporating lessons from other countries to inform our own urgently-needed climate policies, the NTE attacks other countries’ environmental and climate laws on behalf of polluting industries, such as:

• Policies to boost the clean energy transition. The report takes aim at a number of climate-related policies in the EU, including its Renewable Energy Directive, Deforestation-Free Supply Chain Regulation, Eco Design for Sustainable Products Regulation, and Sustainable Aviation Fuel Regulation, which require industry to meet sustainability guidelines. The report also attacks the EU’s Carbon Border Adjustment Mechanism (CBAM) regulation, which went into effect in January 2026, and the UK’s proposed CBAM, scheduled to commence in 2027, which levy charges on embedded emissions of certain imported products to incentivize lower emission production. 
• Green certification and local content policies, including the UAE’s green certification program, which gives priority government services (tax exemptions, subsidies, free trade zone benefits) to industries that use sustainable materials and methods, and India’s domestic content requirements for renewable energy government procurement contracts.
• Policies to tackle plastic pollution, including Canada’s Zero Plastic Waste Agenda; United Arab Emirates ban on some single use styrofoam products, such as cups and lids; Dominican Republic’s regulations prohibiting import of non-biodegradable straws and cutlery; Oman’s regulation on single-use plastic bags; Cote d’Ivoire’s regulations on import of plastic bags; and Chile’s plan to implement regulations to address single use plastic in bottles (which was successfully derailed by the U.S. through negotiation). 

Public Health:

In keeping with the Trump administration’s unscientific public health policies as well as the administration’s desire to promote the interests of Big Pharma and Big Ag, the report attacks several critical public health policies from around the world. This includes:

• Drug pricing regulations and processes in Canada, the EU, India, Australia, and New Zealand, which aim to enhance access to lifesaving medicines. 
• Regulations in several countries, including Bangladesh, GCC countries, and Ukraine, on the sale of energy / sugary drinks, including restrictions on advertising and the sale of these products to minors.
• Restrictions on the import of genetically engineered (GE) food in the EU, Mexico, Peru, Russia, Serbia, Taiwan, Turkiye, Ukraine, UK, Angola, Ethiopia, Guatemala, UAE, India, Kenya, and Korea.
• Regulation of pesticides in Vietnam, China, the EU, Mexico, Nigeria, Norway, Pakistan, Taiwan, Turkiye, and the UK.
• Restrictions by the EU, Thailand, China, Russia, and Taiwan on the use of growth hormones and beta-agonists such as ractopamine to treat beef and pork products. 
• Safety and reporting regulations on the import of infant formula in Ethiopia, India, and Colombia
• Regulations related to chemicals, including the EU’s “precautionary” REACH chemical regulation, new hazard classification, labeling, and packaging of chemicals; and regulation of endocrine disruptors; Canada and the EU phasing out Per- and polyfluoroalkyl substances (PFAS), also known as “forever chemicals” that cause cancer, fertility issues, acid rain, air pollution bioaccumulate in wildlife and fish, and more; and chemical regulation requirements in Korea and Turkiye.
• Indonesia’s mandate for testing heavy metals in cosmetics; Kuwait’s stipulation for health certificates disclosing the country of origin for imported cosmetics, food, and pharmaceuticals; the EU’s regulations on antimicrobial resistance and veterinary medicinal products.

Additional Public Interest Policies:

Shockingly, the report targets South Africa’s anti-discrimination and equal opportunities regulations that seek to ensure greater participation of workers and historically marginalized communities in the corporate sector. Elon Musk criticized South Africa’s regulations earlier this year, claiming that Starlink is “not allowed to operate in South Africa simply because [he’s] not black [sic].” Taken together with President Trump’s unhinged claims about apparent “genocide” against white South Africans, the inclusion of these regulations in the NTE report is a worrying sign that the U.S. government intends to use trade tools to push its ‘anti-diversity’ agenda globally.

The report also targets halal certification laws in several majority Muslim countries, notably Brunei, Egypt, the UAE, Kuwait, Oman, Qatar, and Saudi Arabia.

Conclusion

The 2026 NTE Report makes it clear that the Trump administration’s primary motivation behind its trade policy is to protect the profits of big U.S. companies. The brazen attacks against a range of crucial public interest policies, ranging from digital rights to public health regulations, reflect the unfortunate anti-people policies of this administration. 

Countries across the world should be free to adopt measures to protect citizens’ fundamental rights and consumer safety — without having such measures challenged purely to enable greater corporate profit. And they should not feel beholden to undermine their public interest protections because of the deals they signed under threat of Trump’s sweeping tariffs, especially since those tariffs have now been ruled illegal by the U.S. Supreme Court.

While the Trump administration has made it clear that it intends to double down on its coercive trade policies, including through the use of alternative tariff authorities, we stand in solidarity with civil society around the globe in urging urge countries to stand up to Trump’s bullying and continue to press ahead with important policies to hold Big Tech accountable and to protect their environment and the health of their people.

April 1, 2026

EPIC Act Would Be A Multi-Billion Dollar Pharma Windfall At The Expense of Seniors

By Sarah Karlin-Smith

Key takeaways:

Big Pharma is pushing to undermine Medicare drug price negotiation and let corporations price gouge for longer periods, potentially costing taxpayers and patients tens of billions of dollars.

Longer delay periods proposed under the EPIC Act would shrink the time negotiated prices are available for some drugs, while eliminating Medicare drug price negotiations entirely for others.

Six out of the eight (75%) small molecule drugs selected for Medicare drug price negotiations this year, representing more than $11 billion in annual Medicare spending, would have been excluded had the EPIC Act been in place.

• The Inflation Reduction Act (IRA) for the first time empowers Medicare to negotiate drug prices directly with pharmaceutical manufacturers.
• The Congressional Budget Office (CBO) estimated that in the first six years negotiated drug prices are available through Medicare, the government will save nearly $100 billion.
• Medicare enrollees will save billions more through lower premiums and reduced out-of-pocket costs that stem from negotiations.
• Medicare has already negotiated lower prices for 25 drugs, and this year it is negotiating with manufacturers of 15 more drugs to obtain lower prices.

Big Pharma aims to Undermine Drug Price Negotiations

• Now, through the EPIC Act, drug corporations are pushing to gut the law so patients would be forced to wait years longer before receiving price relief on expensive drugs.
• When Congress passed Medicare drug price negotiation, Big Pharma was able to extract a major concession: Medicare negotiated prices for new drugs would not be available until they had been on the market for 9 years (or in some cases longer).
• Now pharmaceutical companies are maneuvering to delay negotiation even longer.
• Lengthening the negotiation delay period would keep prices higher for longer, costing taxpayers and patients tens of billions of dollars.

Impact of Pharma’s Proposed Delay on Drugs Selected for Negotiation

Medicare would have been prohibited from negotiating prices for six out of the eight small molecule drugs selected in 2026 for the third round of Medicare’s Drug Price Negotiation Program (MDPNP) if the 13-year delay that Big Pharma is pushing was already included in the law, costing seniors and taxpayers billions of dollars (see Table 1).

Previous analysis found that had EPIC been in place, Medicare would have been prohibited from negotiating lower prices for five out of the 10 drugs selected in the first year of the program, representing more than $37 billion in annual gross Medicare Part D spending, and eight out of the 15 drugs selected in its second year, representing more than $28 billion in annual Medicare spending.

The latest group of small molecule drugs selected for Medicare’s price negotiation program highlights that pharma companies get too many years of government-granted monopoly pricing power, not too little. If EPIC was implemented the pocketbooks and health of hundreds of thousands of Americans who struggle with cancer, HIV, depression, Alzheimer’s and schizophrenia would suffer at the expense of multi-billion and even trillion-dollar drug companies that have more than earned a fair return on investment on the medications at issue.

Small molecule drugs are eligible for selection to the MDPNP seven years after FDA approval, with the negotiated prices taking effect nine years post approval. In comparison, biologic drugs currently get 11 years on the market before they are eligible for MDPNP selection, with the negotiated price not taking effect until year 13.  The drug industry and its allies in Congress argue that this difference makes small molecule treatments subject to a “pill penalty,” that will disincentivize the research and development of these medicines.

But the “pill penalty” is nothing more than a pharma industry myth. Research has found that the trend of venture capital investment in small molecules has not dropped since the MDPNP’s passage. Instead, investment is going up. More broadly, there is no evidence that the IRA has negatively impacted the willingness of investors or companies to invest in pharmaceutical development.

On the other hand, there is ample evidence that biologics do not need extended protection from price negotiations compared to small molecules. A better solution for patients and taxpayers would be for Congress to eliminate the negotiation delay period and allow for negotiation of all brand name small molecule and biologic treatments as soon as they reach the market.

Most countries negotiate the prices of brand name drugs shortly after their launch. The IRA’s drug price negotiation efforts, while meaningful, are still far too generous to the drug industry. The small molecule drugs selected this year for negotiation will have had anywhere from 10 to 16 years of market monopolies before government-negotiated prices take effect (and will continue not to face generic competition until patents and exclusivities expire or are ruled invalid, even after negotiated prices take effect). Yet in just one year many of these drugs account for enough net revenue in the U.S. alone to cover the industry’s exaggerated estimate of the $2.8 billion it says it costs to bring a drug to market, which factors in the risk of failure and costs of foregone profits from other capital investment. All of the drugs that would be delayed in negotiation by EPIC easily make enough in a year to cover the median total R&D costs of $150 million estimated by independent experts.

Delaying the negotiation of small molecule drugs as called for under EPIC would result in some of these drugs never having a negotiated price as generic competition would come on the market before or during the negotiation period, such as in the case of Johnson & Johnson’s prostate cancer treatment Erleada. The timing of Erleada generic entry would be doubly problematic as Medicare would still be forced to select Erleada for negotiations in early 2030. Once generics enter in September of that year, if CMS determines that the generics are being “bona fide” marketed, Medicare must suspend negotiations. However, Medicare would not be able to replace Erleada with another drug eligible for negotiation, meaning Medicare loses out on savings from lowering the price of another monopoly product for seniors.  In other cases, like with Eli Lilly’s Verzenio for breast cancer, the government would go through the time and effort of negotiation only for generic competition to launch about the same time, meaning the government would get little benefit from the time and effort it spends negotiating the cost of the drug.

These cases are not anomalies. Studies have shown that small molecule drugs typically enjoy market exclusivity for around 12–14 years before generic competitors enter the market. Indeed, even with current delay periods, three out of the 10 drugs selected in the first year of the negotiation program will be removed from it after only one year of negotiated prices being in place.

While negotiation delay periods prohibit the government from negotiating lower prices for drugs newly on the market, drug corporations are spiking drug launch prices to new heights year after year. Drug corporations set the median list price for newly launched drugs in 2024 at $370,000, up from $300,000 in 2023, which was up from $220,000 in 2022, and $180,000 in 2021. From 2008 to 2021, drug companies increased drug launch prices exponentially by 20% per year. Further reforms that build on the progress of IRA to address prescription drug prices at launch are needed.

An overwhelming majority of Americans support Medicare negotiating prices for more drugs, not exempting more drugs from negotiation. Policymakers should reject attempts from Big Pharma and its allies to weaken Medicare drug price negotiation and instead strengthen the program, including by eliminating negotiation delay periods.

Table 1: Small Molecule Drugs Selected for Medicare Drug Price Negotiation Program, Initial Payment Applicability Period (IPAY) 2028

Drug	Negotiation Eligibility Under EPIC (selection year/initial price application year)	Medicare Spend (Part B & D from 11/2024-10/2025)[i]	Total Medicare Beneficiaries (11/2024 – 10/2025)	2025 U.S. Net Revenue	2025 Worldwide Net Revenue	Total Lifetime Net Revenue[ii]	Expected Generic Entry
Biktarvy (bictegravir/emtricitabine/tenofovir alafenamide) (Gilead)	2031 (IPAY 2033)	$3.904B	101,000	$11.467B	$14.334B	$71.802B	4/1/2036
Erleada (apalutamide) (J&J)	2030 (IPAY 2032)	$1.948B	19,000	$1.453B	$3.574B	$13.224B[iii]	9/2030
Kisqali (ribociclib) (Novartis)	2029 (IPAY 2031)	$1.578B	17,000	$2.975B	$4.783B	$13.542B	2031[iv]
Verzenio (Eli Lilly)	2029 (IPAY 2031)	$1.429B	15,000	$3.464B	$5.723B	$20.475B[v]	2031
Lenvima (Lenvatinib) (Eisai)	2028 (IPAY 2030)	$1.088B	10,000	$1.5B[vi]	$2.063B[vii]	$10.687B[viii]	7/1/2030
Rexulti (brexpiprazole) (Otsuka, Lundbeck)	2027 (IPAY 2029)	$1.075B	119,000	$1.93B[ix]	$2.088B	$9.12B	4/12/2033

Methods/Sources: Negotiation eligibility under EPIC was determined by looking at the first approval date for a non-orphan indication of the drug at FDA’s drugs@FDA database. Medicare’s IPAY 2028 fact sheet was used to get data on Medicare Part B and D prescription drug expenditures and number of Medicare enrollees who used the drug. Drug company SEC filings (10-K, 20-F) and other financial reports were used to obtain 2025 U.S. revenue figures, 2025 worldwide revenue figures and lifetime revenue figures. A combination of drug company SEC filings, court documents, press releases and FDA Orange Book patent data were used to determine the date of expected generic entry.

[i] Medicare spend is gross spending

[ii] Lifetime revenue calculated through December 2025

[iii] JNJ did not break out 2018 sales for Erleada (drug approved 2/14/2018)

[iv] Absent clear information disclosed by company, or lawsuit, estimated drug would face generic competition 13 years after launch based on this research: https://www.tandfonline.com/doi/full/10.1080/13696998.2021.1952795#abstract

[v] Lilly did not break out 2017 sales for Verzenio (drug approved 9/28/2017)

[vi] Data is from fiscal year ending 3/31/2025 (FY2024) for North America

[vii] Data is from fiscal year ending 3/31/2025 (FY2024)

[viii] Lenvima was approved 2/13/15. 2015 sales used in total do not include February and March of 2015

[ix] All Rexulti revenues taken from Otsuka’s filings

 

 

 

 

 

 

 

Testimony: Rhode Island should limit insurer support for the fossil fuels driving up costs

Testimony of Elyse Schupak in support of S.B. 2646: the Rhode Island Insurance Market Protection Act

Good afternoon, my name is Elyse Schupak and I am a policy advocate with Public Citizen, a nonprofit consumer advocacy organization working to advance the public interest in government. 

I am here to testify in support of Senate Bill 2646: the Rhode Island Insurance Market Protection Act.

The impacts of climate change are having significant destabilizing effects on property insurance markets in Rhode Island and across the country. 

In response to increasingly frequent, severe, and costly climate disasters, property insurers are raising rates at a rapid pace. Between 2021 and 2024, property insurance costs in Rhode Island increased by 20 percent, outpacing inflation by 7 percent. Rising costs are creating financial strain for many homeowners and renters. Research from the Federal Reserve Bank of Dallas found that rising property insurance costs are driving up household indebtedness and increasing mortgage and credit card delinquencies. 

In some geographies, high quality private insurance is unavailable entirely as major insurers have stopped writing policies in many climate-vulnerable areas. Lack of insurance creates economic ripple effects for communities. Banks and other mortgage lenders require borrowers to purchase homeowners insurance, meaning the loss of insurance in a community can bring about the loss of other financial services. In a U.S. Senate hearing last year, Federal Reserve Chair Jerome Powell testified that as a result of escalating climate disasters, “If you fast forward 10 or 15 years, there will be regions of the country where you can’t get a mortgage, there won’t be ATMs, banks won’t have branches and things like that.”

Despite the risks climate change poses to property insurance markets and the financial wellbeing of policyholders and communities, insurers continue to underwrite and invest in projects and activities that worsen the climate crisis. The largest U.S. insurers each collect upward of $500 million in annual premiums from fossil fuel companies and through their aggregate $9 trillion investment portfolios, insurers finance fossil fuel companies and other carbon-intensive industries.

While homeowners and renters buckle under the pressure of rising insurance costs, property insurers are making record profits. In 2024, the industry took in $25 billion in underwriting profit and $164 billion in investment income. 2025 is expected to be another windfall year for the property insurance industry. S&P Global estimates insurers made nearly $60 billion in underwriting profit last year. 

The Rhode Island Insurance Market Protection Act will address the role insurance companies play in worsening the climate crisis and financially straining households through rate increases and nonrenewals, all while making record profits. 

The bill will prohibit insurers from underwriting new fossil fuel projects and expanding fossil fuel investments; and will require insurers to phase out their existing fossil fuel underwriting and investments by 2035. The bill will also address insurer withdrawals—prohibiting insurers from leaving the state unless they can prove withdrawal is necessary to preserve their solvency or the insurer can identify replacement carriers for current policyholders. 

Public Citizen urges the committee to pass Senate Bill 2646. Thank you for your time and attention to this issue. 

Up, Up and Away: Explaining Why CEO Pay Soars

On Nov. 6, 2025, Tesla shareholders approved a record shattering compensation package for CEO Elon Musk valued at $1 trillion. They approved this despite a poll showing average Americans opposed this gargantuan sum by a two-to-one margin;[1] despite recommendations of a “no” vote by the nation’s largest proxy advisory firms;[2] and despite Musk’s recent public displays of idiosyncratic behavior, as described in part one of this analysis.[3]

Musk’s $1 trillion package did not emerge from sheer madness; in fact, CEO pay has soared dramatically in the last half-century, culminating in this new $1 trillion frontier. This trend of soaring CEO compensation and, in particular, Tesla’s off the rails package for Musk, however, is completely out-of-sync with investor and public sentiment.  Why? Did CEOs work less hard back in the 1960s even though American industry led the world in automobile production, pharmaceutical development, technology, and more? Have CEOs become much more valuable relative to the line workers who design and manufacture automobiles, or the software engineers who produce technological breakthroughs? Is their performance better?

Evidence shows that pay has little connection to performance or to the efforts of the CEO.[4] Harvard Law School Professors Lucian Bebchuk and Jesse Fried documented this disconnection two decades ago in their 2005 book Pay Without Performance.[5]

“In all but a few glaring instances, executive pay is … not linked to how the company is doing,” explained Ira Weinberg, Washington-based practice director for executive compensation at Hay Management Consultants. “There is rarely an offsetting decrease in compensation when earnings fall.”[6]

Nor do the senior executives seem to be working harder than their peers of a half-century ago. For example, Elon Musk has spent considerable time away from Tesla, running SpaceX and more recently, Twitter/X, followed by the Department of Government Efficiency (DOGE).

Public Citizen explored the dysfunctions behind the disconnection between CEO pay and CEO performance. We find these factors at play:

• Captured boards, a fatal problem since they determine CEO pay;
• Conflicted institutional voters who do not vote in their investor/clients’ interests;
• Lax state laws that protect corporate management at the expense of the public;
• The rise of share price as the sole measure of corporate success;
• Conflicted CEO pay consultants;
• Falling individual tax rates; and
• The rise of buybacks as a common share price manipulation tactic.

Governance Conflicts

The example of Tesla highlights what pay critics have long observed, namely, that the governance machinery that determines CEO pay is broken.

The individuals who determine a CEO’s pay are directors of the corporation’s board. The board is elected by shareholders and, according to fiduciary law, reports to shareholders. They should hold the CEO accountable for major decisions and set his pay.

But the reality is that many board members are either docile or essentially captured.  A full 35 percent of board members are or were themselves CEOs of other companies.[7] It’s in their interest to increase CEO pay generally, a good example for their own board members, who would be motivated to match that level of pay. It’s also not in their interest to rock the boat, a bad example for their own board members. Should they object to high pay where they oversee a CEO, their own board members may object to theirs. Another 14 percent of board directors are insiders, managers of the firm, that is, subordinates of the CEO. They are certainly not a group well motivated to challenge their boss or reduce CEO pay. [8]

Board members don’t face a standard political election where there might be two or three candidates for a single board slot, and there is no venue to campaign on a platform of reining in compensation expense or otherwise putting shareholders first. In all but rare cases (such as when a large, activist shareholder attempts to force major change at a company and sponsors a dissident candidate), there is one candidate for each board slot.

These candidates are recruited by the board, not volunteers who express interest, perhaps because they are concerned with runaway CEO pay. The board uses company resources (hired headhunters) to identify the candidate. It seems unlikely a company-hired headhunter would intentionally recruit someone bent on reversing the course that the incumbent board members have set on escalating CEO pay. Most headhunters have themselves typically come from careers where they’ve advanced high in their respective fields, a sign of thriving within establishment norms. [9]

Once on the board, the incentive to remain there and not rock the board is palpable. The pay for directors is generous, averaging $336,352, according to the 2025 Spencer Stuart annual “Board Index” report. [10] For this sum, the obligations are not extensive. The average corporate board met 7.1 times in 2024. [11] If the meeting lasts all day, that’s $47,373 a meeting, half the median annual income for an entire American household.[12] The maximum work, including non-meeting conversations and research is no more than 250 hours a year, or six weeks, according to a PWC survey.[13] That’s $1,264 an hour. For many, that may be compensation worth being quiet in a board meeting to keep, especially on such a sensitive issue as how much the CEO makes. Tesla board members, as noted in the first part in this series, receive millions.

According to Harvard Law School Prof. Lucian Bebchuck, a leading executive compensation scholar,

“CEOs and their management teams have considerable influence over boards. Directors have both financial and nonfinancial incentives to favor executives. Social and psychological factors tend to reinforce these incentives. The cost to directors of pay arrangements that hurt shareholders is low, and directors therefore have little economic incentive to resist a CEO’s compensation demands. Directors also devote too little time to their board positions to perform effectively the role of informed arm’s length bargainers.”[14]

Opined Robert Monks, considered one of the deans of corporate governance and co-founder with Nell Minow of Institutional Shareholder Services, a proxy advisory firm, “You have a situation in which, essentially, people pay themselves.”[15]

Graef Crystal, the leading compensation consultant who had negotiated the record-setting pay plan for Michael Eisner at Disney, then subsequently became a leading, acerbic critic, concluded that it’s rigged game. “When the company’s stock goes up, the chief executive views himself as a hero. And when it goes down, politicians are blamed, “it’s Janet Yellen’s or Barack Obama’s fault,” said Crystal.[16]

Crystal penned a 1991 book documenting the ways boards indulged CEOs, titled In Search of Excess: The Overcompensation of American Executives.[17][18]  In Crystal’s view, “Executive compensation, American-style, is the ultimate insider’s game: everyone involved wins—except the shareholders.” Crystal claims that the CEO appoints his or her friends to the board, caters to them, keeps them happy, pays them handsomely, and expects to have the favor returned when it’s time for the board to ratify a compensation plan. The CEO hires high-priced compensation consultants, who report that the market for executive talent requires the board to deliver yet another tidy fortune to the CEO. Since these compensation consultants define what the market for executive talent is or is not, this finding is good news for CEOs everywhere—and for the consultants who line their own pockets by telling CEOs exactly what they want to hear.[19]

Concluded the pithy Crystal, “How are pay levels negotiated at American companies? The bargaining is done essentially by the chief executive officer, standing in front of the shaving mirror.”[20]

Some directors’ pay packages are so outrageous as to prompt lawsuits, such as the Musk case, mentioned in our previous report.  But courts have rarely voided compensation. It does happen in rare occasions, though. The directors of Tesla, who previously awarded CEO Elon Musk $2.6 billion in stock options, awarded themselves more than $735 million.[21] That’s money they ultimately agreed to return after a lawsuit by Telsa shareholders.[22]

In addition to conflicted board directors, shareholders with concerns about CEO pay face roadblocks.  Investors are allowed to vote up or down on executive compensation packages, known as “say on pay.” This was one of the reforms of the 2010 Dodd-Frank Wall Street Reform and Consumer Protection Act. However, this vote is non-binding. Boards need not re-write the compensation contract after a disapproval vote from shareholders. Some boards do reduce pay after a sizeable “no” vote. But the frequency of a majority “no” vote is relatively low—sometimes fewer than 10 companies per year suffer such a setback.  The record number of majority “no” votes was set in 2020 at 16.[23]

One reason for this, even in the face of the glaring problem of escalating CEO pay and its disconnection with performance, is the dominance of large institutional investors, namely mutual funds, in corporate share ownership. Only 25 percent of a typical company’s stock is held by individual investors; the balance is owned – and voted on – by these  institutions.[24]  Mutual funds such as Blackrock, Fidelity and Vanguard ostensibly own stock for the benefit of their investing clients, but they have no obligation to ask how their investing clients might vote on any issues before the annual meeting, including CEO pay packages.

What’s more, and most importantly, mutual funds are hamstrung by a conflict of interest: in addition to serving individual investors, mutual fund companies may also serve as advisors to corporate-sponsored pension funds.[25]

Researcher R. Christopher Small explained,

“Mutual funds have a fiduciary responsibility to act in the interests of their shareholders. Shareholder proposals provide one mechanism via which mutual funds can influence firm policies to benefit shareholders. However, mutual funds benefit when they receive pension fund business from firms, which creates a potential conflict of interest that creates an incentive for fund managers to support firm management and to vote against shareholder proposals.”[26]

Asserted researcher Ying Duan,

“Corporate pension plans frequently employ [mutual funds] as trustees or other service providers. The trustee relationship brings large capital inflows to family funds, creating motives to attract and maintain pension clients and compromising the funds’ role in corporate governance, because they are tempted to please rather than discipline management in order to maximize assets under management (rather than portfolio performance). This can apply even if the [mutual fund] is not currently tied to the firm – the potential of securing lucrative pension businesses can be strong enough a motive. In proxy voting, conflicted [mutual funds] are expected to support management and/or oppose activist shareholders more than other mutual funds.”[27]

Yet another study found “business ties with portfolio firms influence mutual funds’ proxy voting.”[28]

Meanwhile, those individual investors who believe the CEO is truly pillaging a company will rationally sell the stock altogether. That eliminates their ability to vote against outsized pay packages.

State Laws

The fact that states, not the federal government, determine corporate rules further debases rational governance. Even though the modern, large corporation operates across state borders, and often  internationally, states regulate their governance. Most large companies incorporate in Delaware, known for its corporate-friendly laws, as well as its robust and experienced court system. This created a race to the bottom effect where states that might consider improving corporate governance risk losing incorporations, and the associated fees. Delaware earns so much from its incorporation fees that it maintains low personal income tax rates and charges no sales tax. In 2024, for example, the state took in $2 billion from incorporation fees, about a third of all tax revenue.[29] By contrast, New York, where many of these same Delaware-incorporated companies maintain their physical headquarters, incorporation fees make up 0.0003 percent of total state tax revenue.[30]

Musk’s $1 trillion paycheck came after Musk chose not to surrender to the Delaware courts. After the Delaware judge invalidated his Tesla pay package – calling it “an unfathomable sum,”[31] – Musk derided her and Delaware corporate law. While Delaware built a reputation for pro-corporate laws, Musk has moved the goal posts in the race to the bottom. He then led reincorporation of Tesla and SpaceX in Texas. [32]

That exodus sent tremors through states. Presumably to prevent the next Tesla from abandoning incorporation in their respective states, Delaware, Texas, and Nevada changed their corporate laws to make them more favorable to corporate insiders and less favorable to retirement savers and other investors who want to protect their investments.

Delaware also changed its laws to make it easier for corporate insiders to escape scrutiny for conflicted transactions (when corporate insiders are on both sides of the transaction) that may harm regular shareholders by, among other changes, creating a generous safe harbor for conflicted transactions, redefining what it means to be an independent director and controlling shareholder, and limiting what documents shareholders can request from corporations.[33] Even though Musk’s companies were no longer incorporated in the state, Delaware Governor Matt Meyer said that he wanted the state to “get it right for Elon Musk.”[34] Many institutional investors opposed the bill,[35] while the private equity industry and lawyers representing corporate insiders lobbied for it.[36] Delaware’s reaction to Musk’s departure represented nothing particularly novel; states have long “raced to the bottom” to attract incorporations. The year before the Musk contest, for example, Delaware passed a law that gave venture capital and other large, early investors rights that allow them to second guess and effectively control boards of directors.[37]

Texas approved three laws following the Musk pay decision undermining the rights of minority shareholders and insulating corporate insiders from accountability: one allowing corporations to amend their bylaws to require a 3 percent ownership threshold to bring shareholder derivative lawsuits; another allowing corporations to amend their bylaws to require a 3 percent or $1 million ownership threshold to file shareholder proposals; and a third requiring proxy advisors to declare they incorporated “nonfinancial factors” and “subordinated the financial interest of shareholders” if they take into account environmental, social, and/or governance factors when making recommendations to clients to cast votes against the recommendations of corporate management.[38]

Nevada also joined the race to the bottom of state corporate law. Andreessen Horowitz, a prominent venture capital firm and major cryptocurrency investor, announced it was leaving Delaware for Nevada and encouraged tech startups to do the same.[39] Andreessen-associated authors penned an article encouraging the move pointed to a lax standard of review of corporate decision-making enshrined in Nevada statute, broad protection of executives and boards from liability, and a significant ownership threshold for shareholders to be able to request certain documents from the company as reasons for incorporating in Nevada instead of Delaware. These reasons add up to one main reason: more power for corporate insiders and less power for regular shareholders to serve as a check on decisions that affect their investments, even when they harm beneficiaries and constituents.

Recent Federal Changes

At the federal level, Trump appointees are working to limit the rights of regular shareholders to hold corporate insiders accountable. Early in 2025, the Securities and Exchange Commission (SEC) changed its policy to make it easier for companies to exclude shareholder proposals from their proxy statements.[40] The agency also greenlit public companies to include a mandatory arbitration clause in their governance documents.[41] Mandatory arbitration requires a harmed shareholder to use secretive, corporate-biased arbitration and bars them from suing in court. The agency also weakened its own ability to police financial markets by prohibiting its Enforcement Division from launching investigations without a Commission vote approving them.[42] Meanwhile, the U.S. House of Representatives advanced a package of bills that it passed last Congress that would further weaken shareholder rights and undermine the ability of the SEC to mandate companies to disclose information that would allow investors to make more informed decisions.[43]

In sum, CEO pay is soaring because there is no mechanism to stop it; in fact, current governance conflicts seem to promote pay escalation.

Shareholder Primacy

Several new factors add to the acceleration of rises in compensation. Former CEO Steven Clifford and veteran Wall Street observer Nicholas Lehmann in their respective books argue that CEOs’ focus on priorities changed in the 1980s. This change followed persuasive academic publications by an influential business school professor extolling shareholder primacy. That is, all that matters is the price of a company’s stock.

In his book, “The CEO Pay Machine,” former broadcast industry executive Clifford points to a 1976 series of articles by Rochester University Professor Michael Jensen called “Theory of the Firm.” In short, Jensen called for using share price as the sole, determining factor in setting CEO pay. “When I was in business school from 1966 to 1968,” recounts Clifford, “we studied cases that illustrated that good citizenship was usually good business.” Affirming this view, in 1981, the Business Roundtable, which is composed of the CEOs of the largest businesses, issued a statement that management must balance the interest of various stakeholders, that included customers, employees, and the community, along with shareholders. [44]

It was about this time that Jensen, who ironically later became a critic of private equity, became prominent.[45] Lehmann in his book “Transaction Man,” recounts how Michael Jensen argued that corporations were not efficient, profit-maximizing machines, but inefficient bureaucracies “whose chief executives ensured corporate boards were stuffed with their cronies, and ruled their fiefdoms based on friendships, whims, and on ‘the attractiveness of the office staff,’” summarized Lehmann.[46] Jensen became the most outspoken figure in the shareholder primacy movement, extolling the singular focus on stock prices. [47].[48]

Jensen’s major contribution to scholarly understanding of business management was what he termed the “principal-agent problem.” Put most simply, managers weren’t accountable to owners. Owners, in this case, were the shareholders, the principals. The managers were the executives, including the CEO, and the agents of the principal/shareholders. Insulated from true shareholder/principal suffrage, CEOs could be lazy and overpaid.[49]

While this concept of lazy, overpaid managers unresponsive to shareholder interest might not seem to be a revolutionary concept or worthy of popular attention, Jensen’s scholarship became convenient to, and thereafter amplified by, a Wall Street operator relatively new to the American corporate landscape in the 1980s: private equity (as it is now called). These new financial operators were derided in the 1980s as corporate raiders, predators,[50] even barbarians.[51] That’s because their corporate takeover deals made them personally rich often at the expense of the health of the target company.[52] In their transactions, the private equity firms would borrow funds at high rates (junk bonds), many underwritten by Wall Street investment bank Drexel Burnham Lambert. They used these funds to buy a controlling share of a healthy company’s stock. When management opposed the takeover, (making them hostile), the winning bid price won the day. To repay the expensive junk bonds, the raiders directed the newly acquired company to take on debt to repay that expensive transaction-financing the raiders used to fund their takeover. Indeed, the raiders effectively used the target company’s own resources to finance their raid. They primly called them “leveraged buyouts.”  Often, servicing this new debt forced the once thriving company to cut labor, reduce production, terminate philanthropy, and sometimes, declare bankruptcy. The raiders, meanwhile, would charge exorbitant management fees at the target company, ensuring that they would profit even if they bankrupted the firm.[53] During the 1980s alone, more than a fourth of the Fortune 500 companies were subject to takeover attempts, led by the raiders and often financed by Drexel Burnham.[54] [55]

Jensen might have been dismissed as a willing apologist for justifying these private equity bust-up buccaneers. But after another decade watching raiders do little to improve performance by corporate America but much to fatten their own compensation, Jensen turned his ire on these same Wall Street financiers. In one speech, he railed against the “lying, cheating and stealing” in the financial sector.”[56]

Instead of shareholder primacy, in the 2000s, Jensen stressed that business managers must embrace “integrity.” He co-authored a paper on this in 2017. But this time, he did not enjoy the echo chamber of private equity to amplify his thinking. Five years after posting this 2017 work, it had gotten fewer than 50 academic citations. By contrast, his 1976 paper “Theory of the Firm,” which celebrated shareholder primacy, received 66,000 citations.[57][58]

The likes of compensation consultant Graef Crystal and Harvard Professor Michael Jensen may have reversed course but the focus on share price did not flip back to a culture of considering multiple stakeholders.  In a stock market where any investor hopes to profit, the appeal of shareholder primacy became the controlling force. Indeed, some of the primary sources of capital for private equity came from worker pension plans, even though the most prominent victim of private equity were workers.[59] Some labor unions have warned against pension funds allying with raiders and other private equity managers.[60] And, a number of activist groups openly decry the plundering by private equity, funded by pension funds meant to benefit workers most savaged by this sector.[61]

Even as incumbent management derided the raiders’ focus on transient stock prices, the threat of a raid forced even them to internalize a focus on stock price. Writing in the Harvard Business Review, Roger Martin observed,

“The corporate raiders who came to prominence in the early 1980s amplified the effects of these trends. Their activism gave executives an added incentive to pay close attention to the stock price. If they didn’t, a raider could launch a hostile takeover bid, gain control of the company, fire them, and possibly tear the company apart to wring maximum immediate value from it.”[62]

Backfiring Reform

Governance critics also cite a 1993 tax law as another factor boosting pay. As with the irony of Jensen criticizing high pay yet serving to fuel it further, this tax reform was meant to clamp down on overpayments, but fell far short. First, the new law capped the amount of CEO pay that could be deducted as a company expense at $1 million. Then, the law only permitted deductible pay after that $1 million if the compensation was “performance-based,” with metrics approved in a shareholder vote.

“Three things happened,” according to governance expert Nell Minow.

“The first was that every CEO in America got his salary raised to $1 million. The second was that corporate compensation committees, which remained determined to shower money on their top executives, invented a lot of make-believe performance metrics like making the company a ’fun’ place to work..”[64]

Conflicted Consultants

In addition to the rise of shareholder primacy, and the backfiring tax reform effort, “The CEO Pay Machine” author Clifford also blames the rise of pay consultants for soaring and excessive CEO pay. “In the old stakeholder world,” Clifford writes, “pay was guided by the principle of internal equity—how it compared with that of other managers and employees within the firm.” Consultants changed this by comparing the CEO’s pay with that of his peers. Since the consultant wanted to retain and secure other consultancies, it was inevitable that he chose the right “peers,” typically those with high pay. For the same self-interested reasons, the consultant would find other ways to justify higher pay. For the board, writes Clifford, the consultant relieves them of making the difficult and sometimes awkward decision of setting the CEO’s pay. “Can a consulting firm dependent on the CEO for major fees give unbiased advice about what he should be paid? With no intention of disparaging the integrity of the industry, I note that when consultants provided other services to a company, the CEO’s pay was substantially higher.” [65] (Some of these services might include merger or management restructuring ideas.)

Pay consultant-turned-critic Graef Crystal agreed. “I helped create the phenomenon we see today; huge and surging pay for good performance, and huge and surging pay for bad performance, too.”[66]

Falling Tax Rates

Reduced individual income tax rates also contributed to rising CEO pay in the last half century. In 1952, the marginal tax rate for the highest earners was 92 percent. It applied to any income above $200,000. For income above $100,000, the tax rate was 90 percent.[67] It did little good to a CEO to pay him $1 million if $810,000 of the final $900,000 in compensation went to Uncle Sam. In 1964, the top rate was reduced to 77 percent. Then, under the Reagan administration, it was reduced to 50 percent in 1982, then 28 percent by 1988.[68] While income tax rates inched up recently, the million-dollar CEO can pocket most of it.

Buybacks

Another reason for soaring CEO pay: the rise of buybacks. When a firm repurchases its own shares, the act of buying increases the share price. In addition, fewer shares in circulation means that company earnings are allocated across a smaller number of investors. Arithmetically, earnings-per-share are greater when there are fewer shares.  Until 1982, buybacks were uncommon, considered market manipulation. The SEC, under the Reagan administration, changed the rules providing that management disclosed when they personally would buy or sell stock.

Share repurchases, or buybacks, have become a major feature of the stock market. In 2020 alone, companies bought more than $700 billion worth of their own shares.[69] From 2010 to 2019, publicly traded companies spent $6.3 trillion on buybacks. That average is equal to about 100% of the corporate profits of non-financial firms in 2020.[70]  Stock buybacks reached a record $942 billion in 2024, but forecasters expected $1.2 trillion in 2025.

Conclusion

CEO pay is soaring because of insufficient guardrails to rein it in; in fact, current governance conflicts seem to promote pay escalation. Board directors fail to represent shareholder interests as they’re recruited by management, then coddled into compliance with excess pay packages. Boards technically hire pay consultants, but they do more to enable high pay then to bridle it.  Institutional investors fail to represent shareholder interests because they profit from corporate pension management fees. State laws remain toothless because corporate interests overly influence legislatures that are hungry for incorporation fees. And corporate America now follows a compass that points only to share price maximization, ignoring other goals for any responsible economy where corporations figure prominently.

These problems aren’t likely to fix themselves. Congress must intervene with sensible requirements, from tax policy that penalizes exorbitant pay, to real board elections where investors choose between competing candidates, and other important reforms. Public Citizen reviewed these reforms in our report “White Collar Crimes Still Pays.”[71]

Meanwhile, the unfathomable trillion-dollar Musk pay package now becomes the new boundary.

Attribution & Acknowledgements

Bartlett Naylor authored this report and serves as economist for Public Citizen. Michael Tanglis is the research director for Public Citizen’s Congress Watch division and edited this report.

The author wants to thank Natalia Renta for her contributions to this piece, including the analysis of state law on corporate governance. Renta is associate director of Americans for Financial Reform.

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[4] Between 2015 and her final edition in 2023, As You Sow researcher Rosanna Landis Weaver documented what she identified as the 100 most overpaid CEOs each year. She identified this group by using regression analysis comparing what they should be paid, based on total shareholder returns (dividends plus share price appreciation), and what they are paid. For example, in 2022, the Paycom CEO who received $211 million ran into shareholder opposition, who voted “no” in a non-binding vote at the annual meeting. Rosanna Landis Weaver, 100 Most Overpaid CEOs, 2022, As You Sow (2022), https://citizen.short.gy/C6Sxpc.

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[8] Id.

[9] Id.

[10] Id.

[11] Id.

[12] Jessica Semega, Income in the United States: 2021 Census Bureau (Sept. 13, 2022), https://citizen.short.gy/AEhaLT.

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[14] Lucian Bebchuk and Jesse Fried, Pay without Performance, Harvard University (Feb. 2004), http://www.law.harvard.edu/faculty/bebchuk/pdfs/Performance-Part2.pdf.

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Crystal played on the name of a best seller, “In Search of Excellence,” a 1982 book that generally lauded American CEO Tom Peters, In Search of Excellence, Harper Business (1982), https://citizen.short.gy/zh2IKS

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[21] Tesla Directors Agree to Return Excessive Stock Grants, ValueEdge, (July 18, 2023), https://citizen.short.gy/Ol8OXR.

[22]Settlement Approved in “Other” Tesla Litigation, Compensation Standards (Feb. 5, 2025), https://citizen.short.gy/WkrQ8S.

[23] Rosanna Landis Weaver, 100 Most Overpaid CEOs, 2022, As You Sow (2022), https://citizen.short.gy/C6Sxpc.

[24] Bob Byran, Here’s Who Actually Owns The Stock Market, Business Insider (May 25, 2016), https://citizen.short.gy/njlz8b.

[25] Ying Duan, Conflict Of Interest And Proxy Voting By Institutional Investors, Science Direct (Oct. 2021), https://citizen.short.gy/afiLvg.

[26] R. Christopher Small, Do Pension-Related Business Ties Influence Mutual Fund Proxy Voting?

Harvard Law School Forum on Corporate Governance (March 28, 2011), https://citizen.short.gy/CvNaJl.

[27] Ying Duan, Conflict Of Interest and Proxy Voting by Institutional Investors, Science Direct (Oct. 2021), https://citizen.short.gy/afiLvg.

[28] Dragana Cvijanovic, Ties that Bind: How Business Connections Affect Mutual Fund Activism, Journal of Finance (April 14, 2016), https://citizen.short.gy/t1Kc3k.

[29] Jacob Owens, Delaware Explained: State Revenue, Spotlight Delaware (May 28, 2025), https://citizen.short.gy/tvmXx1.

[30] New York’s current budget, The Urban Institute (Dec. 2025), https://citizen.short.gy/phh6qD.

[31] Tom Hals, Judge voids Elon Musk’s ‘Unfathomable’ $56 billion Tesla pay package, Reuters (Jan. 31, 2024), https://citizen.short.gy/IYQeKH.

[32] Mariko Oi, Elon Musk Says Spacex’s Legal Home Moved From Delaware To Texas,

(Feb. 5, 2024) BBC, https://www.bbc.com/news/business-68302228

[33] Michelle J. Annunziata, et. al, Delaware Changes Its Corporate Law: What Litigators and Clients Need to Know about Senate Bill 21, Mayer | Brown (April 3, 2025), https://citizen.short.gy/i5yhQb.

[34] Katie Balevic, Delaware governor tells BI things may ‘need to change’ as companies threaten to leave the state, Business Insider (Feb. 2, 2025), https://citizen.short.gy/U1R0a4.

[35] International Union of Operating Engineers of Eastern Pennsylvania and Delaware et al. Public Investor Letter in Opposition to Delaware Senate Bill 21, (March 7, 2025), https://citizen.short.gy/YfJDnN. Jen Sisson, International Corporate Governance Network. Amendments to Delaware General Corporate Law (Senate Bill 21), (March 11, 2025), https://citizen.short.gy/t5LYbi. Jeff Mahoney, Council of Institutional Investors. Letter on Delaware Senate Bill 21, (March 12, 2025), https://citizen.short.gy/aZlOwB.

[36] Sabrina Willmer, Musk’s War on Delaware Spurs Law Pushed by Private Equity, Bloomberg Law (March 26, 2025), https://citizen.short.gy/GtMNeM.

[37] Senate Bill 313. 152nd General Assembly (2023 – 2024), https://legis.delaware.gov/BillDetail/141480.

[38] Niko Gallogly, New Texas Laws Open a Wild West for Corporate Governance, New York Times (Aug. 16, 2025, https://citizen.short.gy/zhCR5b.

[39] Jai Ramaswamy, Andy Hill, and Kevin McKinley, We’re Leaving Delaware, And We Think You Should Consider Leaving Too, Andreessen Horowitz (July 9, 2025), https://citizen.short.gy/kDsaz0.

[40] See Caroline Crenshaw, Statement on Staff Legal Bulletin 14M, U.S. Securities and Exchange Commission (Feb. 12, 2025), https://citizen.short.gy/DdAbLA.

[41] Declan Harty, SEC grants corporate America new power in shareholder fights, Politico (Sept.17, 2025), https://citizen.short.gy/38qTJp.

[42] US SEC revokes staff’s authority to launch formal probes, notice says, Reuters (March 11, 2025), https://citizen.short.gy/gK6aCH.

[43] Re: Full Committee September 10th Proxy Power and Proposal Abuse: Reforming Rule 14a-8 to Protect Shareholder Value Hearing, Americans for Financial Reform Education Fund, (Sept. 8, 2025), https://citizen.short.gy/mUJL1S.

[44]Thomas Hemphill, The Business Roundtable and ‘Stakeholder Capitalism’ — a Retrospective, Inside Sources (Sept. 3, 2020), https://citizen.short.gy/rNEhpN.

[45] Steven Clifford, The CEO Pay Machine, Random House (2017), https://citizen.short.gy/GEjARR.

[46] Nicholas Leman, Transaction Man: The Rise of the Deal and the Decline of the American Dream

Farrar, Strauss and Giroux (September 2019), https://citizen.short.gy/GDXBFV.

[47] Nicholas Leman, Transaction Man: The Rise of the Deal and the Decline of the American Dream

Farrar, Strauss and Giroux (September 2019), https://citizen.short.gy/GDXBFV.

[48] Jensen began his academic career as an assistant professor in 1967 at the University of Rochester’s graduate business school, rising 12 years later to occupy an endowed chair at the New York University where he remained through 1985. In 1985, twenty years into his academic career, he joined the faculty of the Harvard Business School, splitting his time between the Cambridge, Mass. graduate school and Rochester –Faculty, Michael Jensen, Harvard Business School (website viewed August 9, 2023), https://www.hbs.edu/faculty/Pages/profile.aspx?facId=6484

[49] Nicholas Shaxson, On the Birth of the Economist Class and the Untaming of Corporations

LitHub (Jan. 15, 2020), https://citizen.short.gy/WF1Mrf.

[50] Connie Bruck, The Predator’s Ball, (June 1989), https://citizen.short.gy/pSBPr5.

[51] Brian Burroughs and John Helyar, Barbarians at the Gate, (2009), https://citizen.short.gy/HYN9Ic.

[52] Brian Cheffins, The Eclipse Of Private Equity Centre for Business Research, University Of Cambridge, (March 2007), https://citizen.short.gy/sO10bE.

[53] Gretchen Morgenson, These are the Plunderers, (May 7, 2024) Simon & Schuster https://www.amazon.com/These-Are-Plunderers-Runs_and-Wrecks_America/dp/1982191295#

[54] Nicholas Shaxson, On the Birth of the Economist Class and the Untaming of Corporations

LitHub (Jan. 15, 2020), https://citizen.short.gy/WF1Mrf.

[55] Gheorghe Hurduaeu, The History of Junk Bonds and Leveraged Buyouts, Science Direct (2015), https://citizen.short.gy/h8rGuG.

[56] Nicholas Shaxson, On the Birth of the Economist Class and the Untaming of Corporations

LitHub (Jan. 15, 2020), https://citizen.short.gy/WF1Mrf.

[57] Nicholas Shaxson, On the Birth of the Economist Class and the Untaming of Corporations

LitHub (Jan. 15, 2020), https://citizen.short.gy/WF1Mrf.

[58]At a seminar developed along the lines of self-help guru Werner Erhard, he opined. “Most people think I’m an asshole,” a participant recounts him saying. The participant continued, his “personal life was littered with human debris, though he didn’t understand why.” Nicholas Shaxson, On the Birth of the Economist Class and the Untaming of Corporations

LitHub (Jan. 15, 2020), https://citizen.short.gy/WF1Mrf.

[59] Eileen Appelbaum and Rosemary Batt, Private Equity at Work: When Wall Street Manages Main Street, Russel Sage Foundation, (2014), https://citizen.short.gy/wxuduX.

[60] Lee Harris, Labor Slams Pensions for Burnishing Image of Private Equity, American Prospect, (June 17, 2022), https://citizen.short.gy/mS0Acs.

[61]Derek Seidman, Labor Organizers Launch a New Model for the Fight Against Private Equity,  Truthout (May 9, 2023), https://citizen.short.gy/4WKzfw.

[62] Where the raiders led, today’s activist hedge funds have followed, but with far more capital at their disposal. Roger Martin ,  It’s Time to Replace the Public Corporation, Harvard Business Review (February 2021) https://hbr.org/2021/01/its-time-to-replace-the-public-corporation.

[63] Timothy Noah, The Great Divergence: America’s Growing Inequality Crisis and What We Can Do About it, (2012), https://citizen.short.gy/fzuOqM.

[64] Timothy Noah, You Won’t Believe How Crazy CEO Pay Has Gotten Now, The New Republic, (Oct. 6, 2022), https://citizen.short.gy/tScmoy.

[65] Steven Clifford, The CEO Pay Machine, Random House (2017), https://citizen.short.gy/Lnn3lW.

[66] In Memory of Graef Crystal, Kraft & Sussman (2017), https://citizen.short.gy/iwIH6v.

[67] Federal Income Tax Brackets (1952) Tax-Brackest.org, https://www.tax-brackets.org/federaltaxtable/1952.

[68] Tax Policy Center, Historical Highest Marginal Income Tax Rates, Tax Policy Center, May 11, 2023, https://citizen.short.gy/GwCbty.

[69] Id.Stro

[70] Lenore Palladino, William Lazonick, Regulating Stock Buybacks, the $6.3 Trillion Question, Roosevelt Institute (May 2021), https://citizen.short.gy/MKk5PG.

[71] Bartlett Naylor, White Collar Crime Still Pays, (July 21, 2020) Public Citizen, https://www.citizen.org/article/white-collar-crime-pays/#:~:text=Footnotes-,Summary,thousands%20of%20mortalities%20and%20more.

Product Recalls: February 12, 2026 – March 11, 2026

Health Letter, April 2026

Note: Never stop taking a drug that appears on the product recall list without first talking to your doctor or pharmacist. Most recalls are limited to a single manufacturer and may not be related to the version of a particular drug you are taking. If a recall does relate to the version of the drug you are taking, you should not stop taking the drug until you discuss an alternative treatment with your doctor or pharmacist.

For Class 1 recalls, there is a potential for serious injury or death.

For Class 2 recalls, there is a potential for serious adverse events but a lower chance of the drug causing serious injury or death than in a Class 1 recall.

CLASS I

CLASS II

amantadine HCl capsules, 100 mg, 50 capsules (5 x 10) unit dose. Manufactured for: AvKARE. Lot #: 49261, exp. date: 04/30/27.

metoprolol succinate extended-release tablets; 25, 50, 100 or 200 mg; 100- and 1,000-tablet bottles. Manufactured by: Teva Pharmaceuticals. Lot #: 0715J251, exp. date: 12/2026; Lot #: 0716J251, exp. date: 01/2027; Lot #: 0717J251, exp. date: 01/2027; Lot #: 0715J252, exp. date: 12/2026; Lot #: 0716J252, exp. date: 01/2027; Lot #: 0717J252, exp. date: 01/2027; Lot #: 0486G251, 0487G251 or 0488G251, exp. date: 01/2027; Lot #: 0486G252, 0487G253 or 0488G252, exp. date: 01/2027; Lot #: 0718J251, 0729J251 or 0730J251, exp. date: 12/2026; Lot #: 0718J252, 0729J252 or 0730J252, exp. date: 12/2026; Lot #: 0686H251, 0687H251 or 10688H251, exp. date: 02/2027.

midodrine hydrochloride tablets, 5 mg, 50 tablets (5 x 10 blister packs). Packaged and Distributed by: Major Pharmaceuticals. Lot #: N02640, exp. date: 08/2027.

oxycodone hydrochloride tablets, 5 mg, 100-count (10 x 10) blister cards per carton. Distributed by: American Health Packaging. Lot #: 1027932, exp. date: 06/30/2027; Lot #: 1028360, exp. date 08/31/2027.

temozolomide capsules, 5 mg, 5-capsule bottles. Manufactured for: Rising Pharmaceuticals, Inc. Lot #: 1TM0524003A, exp. date: 09/2026.