News & Analysis as of

Appeals Department of Justice (DOJ) Healthcare Fraud

King & Spalding

The Fourth Circuit Rejects a Non-Delegation Doctrine Challenge to the Anti-Kickback Statute

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On July 22, 2025, the Fourth Circuit published its opinion in United States v. Donald Booker, No. 23-461, affirming a 200-month prison sentence for the owner of United Youth Care Services, which billed North Carolina’s...more

A&O Shearman

Pharma Company Brings Latest Constitutional Challenge To False Claims Act In Third Circuit

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On April 29, 2025, a pharmaceutical company filed the latest constitutional challenge to the qui tam provision of the False Claims Act (“FCA”) when it appealed in the United States Court of Appeals for the Third Circuit a...more

Cooley LLP

Compliance Implications for Healthcare Companies Post-First Circuit Decision

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The US Court of Appeals for the First Circuit’s landmark decision in United States v. Regeneron Pharmaceuticals will have some implications for healthcare compliance and defense strategies. In the case, the First Circuit...more

ArentFox Schiff

Investigations Newsletter: Seventh Circuit Reverses AKS Conviction Involving Allegations of Illegal Marketing and Advertising

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Seventh Circuit Reverses AKS Conviction Involving Allegations of Illegal Marketing and Advertising - On April 14, the US Court of Appeals for the Seventh Circuit reversed the criminal conviction of Mark Sorensen after a...more

Harris Beach Murtha PLLC

First Circuit Decision Raises Bar on Anti-Kickback Statute-Premised Liability Under the False Claims Act

The United States Court of Appeals for the First Circuit recently joined the Sixth Circuit (2023) and Eighth Circuit (2022) in holding that the term “resulting from” in the Federal Anti-Kickback Statute (“AKS”) (as amended in...more

Bradley Arant Boult Cummings LLP

First Circuit Joins Other Circuits in Adopting Stricter Causation Standard in FCA Cases Based on Anti-Kickback Statute

On February 18, 2025, the First Circuit joined the Sixth and Eighth Circuits in adopting a “but for” causation standard in cases involving per se liability under the federal Anti-Kickback Statute (AKS) and the False Claims...more

McGuireWoods LLP

First Circuit Adopts “But For” AKS Standard, Leaving Third Circuit Alone in Causal-Link Standard

McGuireWoods LLP on

On Feb. 18, 2025, the U.S. Court of Appeals for the First Circuit adopted the “but for” causality standard for violations of the federal Anti-Kickback Statute (AKS) that give rise to violations of the federal False Claims Act...more

Stevens & Lee

First Circuit Rules Against Government in False Claims Act Case

Stevens & Lee on

On Feb. 18, in U.S. v. Regeneron Pharmaceuticals, the First Circuit Court of Appeals joined the Sixth Circuit and the Eighth Circuit in holding that, for purposes of establishing that a claim for payment of items or services...more

Foley & Lardner LLP

Anti-Kickback Statute Premised False Claims Cases: The “But For” Causation Standard Finds Support from First Circuit

Foley & Lardner LLP on

It’s now 3–1, with the First Circuit (2025) aligning with the Sixth (2023) and Eighth (2022) Circuits finding the meaning of the words “resulting from” — as used in a 2010 amendment to the federal Anti-Kickback Statute (AKS)...more

Husch Blackwell LLP

Are the qui tam provisions of the False Claims Act unconstitutional?

Husch Blackwell LLP on

The qui tam provisions of the False Claims Act allow individuals to file suit on behalf of the United States and to receive a share of the resulting financial settlement or judgment. Filing a qui tam case is not just a formal...more

ArentFox Schiff

Investigations Newsletter: Federal Government Urges Court of Appeals to Uphold Constitutionality of FCA Qui Tam Provisions

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Federal Government Urges Court of Appeals to Uphold Constitutionality of FCA Qui Tam Provisions - In a brief filed earlier this week, the US federal government has urged the Eleventh Circuit Court of Appeals to uphold the...more

ArentFox Schiff

Investigations Newsletter: Seventh Circuit Considers When Legal Marketing Transforms Into Illegal Kickbacks

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Seventh Circuit Considers When Legal Marketing Transforms Into Illegal Kickbacks - On December 4, the US Court of Appeals for the Seventh Circuit heard oral arguments regarding whether the January 2023 jury conviction of...more

ArentFox Schiff

Investigations Newsletter: District Court Declines to Stay Case Pending Resolution of FCA Causation Standard Issue Before Court of...

ArentFox Schiff on

District Court Declines to Stay Case Pending Resolution of FCA Causation Standard Issue Before Court of Appeals - Earlier this week, a Massachusetts federal judge denied a motion to stay proceedings filed by Medtronic,...more

ArentFox Schiff

Investigations Newsletter: Anticipated Landmark Supreme Court Decision May Be Anything But

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Anticipated Landmark Supreme Court Decision May Be Anything But On - April 18, 2023, the US Supreme Court heard oral arguments in a set of highly anticipated cases regarding the scienter—or knowledge—provision of the False...more

McDermott Will & Schulte

McDermott’s Healthcare Enforcement Quarterly - Q1 2022

The healthcare enforcement landscape is shifting quickly. This issue of McDermott’s Healthcare Enforcement Quarterly examines emerging trends and key issues for organizations that may become subject to enforcement scrutiny,...more

The Volkov Law Group

2021 False Claims Act Year in Review: Judicial and Congressional Developments (II of II)

The Volkov Law Group on

As for the Judiciary, the U.S. Supreme Court did not issue any relevant decisions nor grant certiorari in any notable FCA cases in FY21. To the contrary, they denied petitions to review appellate cases of potential...more

Mintz - Health Care Viewpoints

False Claims Act Settlements and Judgments Exceed $5.6 Billion in Fiscal Year 2021

The Department of Justice announced in a February 1, 2022 press release (Press Release) that it obtained more than $5.6 billion in settlements and judgments from civil cases involving fraud and false claims in the fiscal year...more

Bass, Berry & Sims PLC

Courts Grapple with Causation Requirement in FCA Cases Based on Violations of Anti-Kickback Statute

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Congress amended the Anti-Kickback Statute (AKS) in 2010 to confirm that a claim “resulting from” an AKS violation constitutes a false or fraudulent claim for purposes of the FCA. 42 U.S.C. 1320a-7b(g). However, Congress did...more

Morgan Lewis - Health Law Scan

Mere Differences of Judicial Opinion Emerge to Muddle Healthcare Providers False Claims Act Exposure for Mere Differences of...

In the Care Alternatives False Claims Act (FCA) appeal, a panel of the US Court of Appeals for the Third Circuit on March 4 reversed the summary judgment granted to hospice provider Care Alternatives at the district court,...more

Sheppard Mullin Richter & Hampton LLP

The Granston Memo in 2019: Recent Cases Highlight the Granston Memo’s Effectiveness as a Tool to Dismiss False Claims Act Cases

The “Granston Memo” has proven to be a boon again in 2019 for False Claims Act (“FCA”) defendants. In a January 15, 2019 Sheppard Mullin FCA Defense Blog article, we highlighted a growing movement by the Department of Justice...more

Baker Donelson

Disagreements over a Medical Judgment Cannot Form the Basis for Liability Under the False Claims Act

Baker Donelson on

A new federal court decision offers a ray of light to those providers defending false claims actions based on an alleged lack of medical necessity. On September 9, 2019, the United States Court of Appeals for the Eleventh...more

Dorsey & Whitney LLP

Tuomey Settles, Post-Judgment, Alleged Violations of FCA and Stark Law

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The Department of Justice and Tuomey Healthcare have announced a $72.4 million settlement in a lawsuit that the DOJ touts as “another achievement for the [DOJ and DHS] Health Care Fraud Prevention and Enforcement Action Team...more

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