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US Supreme Court Justices Continue to Question Constitutionality of FCA Qui Tam Provision

Justice Kavanaugh issued a concurring opinion in Wisconsin Bell, which Justice Thomas joined, to question again whether the False Claims Act qui tam provision violates Article II of the US Constitution....more

Middle District of Florida Accepts Justice Thomas’s Invitation: FCA Qui Tam Provision Unconstitutional

The Zafirov decision finds that the False Claims Act qui tam provision violates Article II of the US Constitution. On September 30, 2024, in United States ex rel. Zafirov v. Florida Medical Associates LLC, Judge Kathryn...more

US Supreme Court Upholds Broad, but Not Unfettered, Government Authority to Dismiss FCA Cases

DOJ may dismiss qui tam False Claims Act cases at any point, as long as it intervenes in the case and satisfies the deferential Federal Rule of Civil Procedure 41(a) standard. The US Supreme Court, in its 8-1 June 16,...more

Supreme Court Holds FCA Liability Hinges on Defendants’ Subjective Beliefs as to Falsity

The Court unanimously held that a defendant’s subjective belief is relevant to scienter under the False Claims Act, even when a defendant’s conduct is consistent with an objectively reasonable interpretation of the law....more

SCOTUS: Dismissal Not Mandatory for False Claims Act Seal Violation

Rigsby places discretion in the hands of district courts as to whether and how to sanction relators who violate the seal requirement in False Claims Act cases. On December 6, 2016, only a month after oral argument, the...more

SCOTUS Upholds Implied Certification for Some Cases But Imposes “Rigorous Materiality Requirement” for FCA Liability

The decision in Universal Health upholds implied certification but strengthens False Claims Act defendants’ ability to mount a materiality defense. On June 16, 2016 the U.S. Supreme Court issued a unanimous decision in...more

SCOTUS Oral Argument Suggests FCA Implied Certification Theory Is Here to Stay – But Perhaps with Limits

Oral argument in Universal Health indicates Justices disinclined to categorically reject False Claims Act implied certification theory, though may limit its scope. On April 19, 2016, the United States Supreme Court heard...more

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