In this case, the award change was made on Friday May 13th, but as of Monday May 15th, still showed as confirmed on United (greater than 48 hours). The agent essentially confirmed that if nothing had happened, we would have shown up to the airport and my wife told she didn't have a ticket.
Reading through the CoC, the ticket was booked through United.com and confirmed through them - even though the flights aren't operated per se by United, United sells the tickets and establishes a contract when miles are exchanged for a good (travel). I could see if the flight cancelled, was re-scheduled or something else; but essentially in this case United sold - and confirmed - a service which they could not provide.
My thought with the DOT complaint was that since the tickets were booked through United, and the transaction was completed in the US by a US citizen and since United is a registered business in the US, they have an obligation to follow US rules and regulations.
I guess my thought is United is in a partnership with ET - there's ultimately someone at a managerial level that should be able to connect with an ET manager and remedy the situation to uphold the contract that was made (and they confirmed).
Appreciate the replies so far!