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U.S. Supreme Court Hears Oral Argument in False Claims Act Case

The U.S. Supreme Court recently heard arguments in Wisconsin Bell, Inc. v. United States ex rel. Todd Heath, Docket No. 23-1127, a case in which the Court agreed to review whether reimbursement requests submitted to the...more

CFPB’s Funding Mechanism Undergoes Constitutional Scrutiny at U.S. Supreme Court Argument

I. Introduction: On October 3, 2023, the U.S. Supreme Court held oral argument in Community Financial Services Association of America Ltd. v. Consumer Financial Protection Bureau. This case has potentially widespread...more

Considering Voluntary Self-Disclosure After the Federal Government’s Tri-Seal Compliance Note

A perennial debate exists in the white-collar space: do the benefits of self-disclosure outweigh the risks associated with providing the government with a road map to the company’s purported violation? Consistently, the...more

New York Court Determines “Best Interests” Amendment to Insurance Regulation No. 187 is Unconstitutional

On April 29th, a New York Court struck down as unconstitutional the 2017 Amendment to Insurance Regulation 189. The Amendment, commonly referred to in New York as the “best interests” rule, expanded the scope of Regulation...more

Paying or Facilitating Payment of Ransomware Demands May Result in Criminal and Civil Penalties From OFAC

Companies that make or facilitate ransomware payments were given a strong reminder of their due-diligence and compliance obligations by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”). ...more

Liability Dangers for Recipients of CARES Act Funds: Lessons From Past and Present Enforcement Actions

As the country struggles with COVID-19, many companies have applied for and received funds under the CARES Act and its Payment Protection Program (“PPP”). Those companies must understand there are significant risks tied to...more

Supreme Court Holds President Is Not Categorically Immune to State Court Subpoena

In last week’s decision in Trump v. Vance, the Supreme Court addressed for the first time whether a state District Attorney’s Office can issue a state criminal subpoena to a President. Relying on historical examples dating as...more

Supreme Court Rules On False Claims Act Limitations Period

Should relators rejoice? The Supreme Court may have put to rest the vast uncertainty surrounding the applicable statute of limitations in False Claim Act (“FCA”) suits where the government declines to intervene with its...more

Insurers Beware: Choice of Law Provisions May be Overridden by Public Policy Provisions

In answering two questions posed to it by the Ninth Circuit Court of Appeals, the California Supreme Court on August 29, 2019, addressed two significant issues: 1) whether California’s common law notice-prejudice rule is a...more

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