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First Circuit Affirms Dismissal For CVS Caremark Under Public Disclosure Bar

The FCA’s public disclosure bar precludes liability when a relator’s allegations have been publicly disclosed in a list of statutorily enumerated sources. Last week, the First Circuit added to the growing jurisprudence both...more

Supreme Court Upholds Implied Certification Theory of Liability; Imposes Limitations on its Reach

In a unanimous decision on June 16, 2016, the Supreme Court charted a middle course between competing interpretations of the scope of False Claims Act. Universal Health Servs., Inc. v. United States ex rel. Escobar, Case No....more

Sixth Circuit Joins Sister Circuits In Using Arm-Of-The-State Analysis To Define “Person” Under The False Claims Act

The FCA imposes liability on “any person” that makes a false statement in violation of the Act, 31 U.S.C. § 3729(a)(1). Although the Act itself does not define “person,” the Supreme Court has said only that a person cannot...more

First Circuit Takes “Broad View” of Falsity for Pleading Purposes

In a break with other Circuits, the First Circuit recently reaffirmed its broad definition of a “false statement’ under the False Claims Act. United States ex rel. Escobar v. Universal Health Services, Inc., No. 14-1423 (1st...more

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