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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

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

Fourth Circuit May Address Use of Statistical Sampling in False Claims Act Actions

Court has the opportunity to assess the use of statistical sampling/extrapolation as a method to prove FCA liability or damages. Courts require that plaintiffs prove each element of a legal claim with evidence — mere...more

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