News & Analysis as of

Constitutional Challenges Whistleblowers

Warner Norcross + Judd

Federal Court Flags Stark and Anti-Kickback Risks in Physician Pay, Spotlights FCA Constitutional Questions on Appeal

On July 28, the federal district court in the Southern District of Ohio issued a pair of orders in related whistleblower cases under the False Claims Act (FCA): United States ex rel. Murphy v. TriHealth, Inc., et al., No....more

White & Case LLP

The Long and Winding Road: Two Decades of Antitrust Enforcement in Spain

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"Competition forces you to evolve. When everything is easy, you don't improve". ― Rafael Nadal Parera, 1st Marquis of Llevant de Mallorca Introduction - Over the past two decades, Spain's competition enforcement journey...more

A&O Shearman

Pharma company challenges the US False Claims Act: what’s at stake for whistleblowers and government enforcement?

A&O Shearman on

A pharmaceutical company is currently appealing a record USD1.6 billion judgment in the US, arguing that a key part of the US False Claims Act (FCA) is unconstitutional. This case, now before the Court of Appeals for the...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

ArentFox Schiff

Investigations Newsletter: Johnson & Johnson Challenges the Constitutionality of FCA $1.6 Billion Verdict

ArentFox Schiff on

Johnson & Johnson Challenges the Constitutionality of FCA $1.6 Billion Verdict - Following a record $1.6 billion jury verdict for off-label promotion of HIV drugs Prezista and Intelence, Johnson & Johnson (J&J) subsidiary...more

Cranfill Sumner LLP

Supreme Court Cert Denials: Beyond the Headlines

Cranfill Sumner LLP on

While legal analysts focus on landmark Supreme Court decisions each term, equally significant are the cases the Court declines to hear. These certiorari denials often reveal critical jurisprudential trends that shape...more

Lowenstein Sandler LLP

Federal Government Asks 11th Circuit To Reverse Decision Declaring Qui Tam Provision of the False Claims Act Unconstitutional

Lowenstein Sandler LLP on

In October 2024, we wrote about U.S. District Judge Kathryn Kimball Mizelle’s dismissal of a whistleblower action, deeming the qui tam provisions of the False Claims Act (FCA) unconstitutional. The Department of Justice (DOJ)...more

Zuckerman Spaeder LLP

For Whom the Bell Tolls: Does Wisconsin Bell Indicate Waning Support for Invalidating the FCA’s Qui Tam Provisions?

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In the summer of 2023, Justice Thomas suggested in a dissenting opinion in U.S. ex rel. Polansky v. Executive Health Resources that Article II of the Constitution might not permit a qui tam relator to sue in the name of the...more

McGuireWoods LLP

Fifth Circuit Concurrence Adds Voice to FCA Constitutionality Questions

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A first appellate circuit judge has questioned the False Claim Act’s constitutionality. In the Fifth Circuit’s decision last month in United States ex rel Montcrief v. Peripheral Vascular Assocs., P.A., No. 24-50176, — F....more

Womble Bond Dickinson

For Whom the Bell Tolls? The Impact of Wisconsin Bell v. United States ex rel. Todd Heath and United States v. Regeneron...

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The Supreme Court’s decision in Wisconsin Bell v. United States ex rel. Todd Heath clarifies what constitutes a “claim” under the federal False Claims Act (FCA). ...more

King & Spalding

Recent Decisions and DOJ Policy Announcements Signal Key Changes to FCA Enforcement and Litigation Environment

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Recent legal and political False Claims Act (“FCA”) developments signal a potentially turbulent time for the defense of investigations and lawsuits brought under the FCA...more

Seyfarth Shaw LLP

Report From Day 1 of The 2025 ABA OSHA/MSHA Law Conference

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This week we are attending the ABA Occupational Safety and Health Law Meeting in Rancho Mirage, California. The meeting includes representatives from management, labor, and safety professionals, some who previously worked in...more

Husch Blackwell LLP

State-By-State Guide to Ag-Gag Legislation - February 2025

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Several states have made attempts to provide the animal production industry protection against unlawful interference by enacting so-called Ag-Gag laws. A wave of litigation is challenging these laws as unconstitutional,...more

Alston & Bird

False Claims Act FY 2024 Update: Increase in Overall Recoveries, Decrease in Whistleblower Awards – Constitutional Questions...

Alston & Bird on

Our False Claims Act Team highlights key FCA enforcement trends in 2024, including the continued focus on health care fraud by the Department of Justice (DOJ)....more

Burr & Forman

The Future of False Claims Act Qui Tam Provisions

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On September 30, 2024, a federal district court in the Middle District of Florida dismissed a qui tam action under the False Claims Act (“FCA”) on the basis that the FCA’s qui tam provision – which allowed individuals to sue...more

Epstein Becker & Green

In Confirmation Hearings, AG Nominee Pledges to Defend the Constitutionality of the False Claims Act

Epstein Becker & Green on

What may have seemed like an out-of-the-blue question to the casual observer was no surprise to those who represent individuals and entities in the health care and life sciences industries: U.S. Attorney General (AG) nominee...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

Mintz - Health Care Viewpoints

EnforceMintz — Scienter, Causation, and Constitutional Questions: 2024’s Three Key FCA Litigation Issues

In 2024, federal courts issued a number of important decisions in False Claims Act (FCA) cases that are particularly noteworthy for the health care and life sciences industries. We focus here on decisions that further develop...more

Akerman LLP - Health Law Rx

Update: Appellate Showdown Over FCA Qui Tam Provision’s Constitutionality Reaches Eleventh Circuit

As we anticipated in our October 17, 2024, blog, both the Government and the Relator have appealed the district court’s decision in U.S. ex rel. Zafirov v. Florida Medical Associates, LLC, et al. (Zafirov), the first case to...more

ArentFox Schiff

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

ArentFox Schiff on

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

Blake, Cassels & Graydon LLP

Quebec Court of Appeal Rules on the Limits of CPA Professional Secrecy for Financial Whistleblowing

On November 12, 2024, the Quebec Court of Appeal (QCA) rendered a significant decision in Autorité des marchés financiers c. Ordre des comptables professionnels agréés du Québec (available in French only) relating to section...more

Orrick, Herrington & Sutcliffe LLP

The False Claims Act: How a Recent Decision Rejecting Qui Tam Lawsuits May Affect Enforcement

For over 160 years, the False Claims Act has let people bring claims on behalf of the U.S. government alleging fraud. In exchange, those individuals receive a portion of any recovery. In September, a federal district judge...more

Kilpatrick

The End of Qui Tam FCA Claims? How a Federal District Judge Might Have Just Sounded the Death Knell For Whistleblower Lawsuits

Kilpatrick on

A seismic shift in the world of False Claims Act (“FCA”) might have occurred recently in a Middle District of Florida courtroom. On September 30, 2024, Judge Kathryn Kimball Mizelle issued her ruling in US ex rel Zafirov v....more

Perkins Coie

Novel Decision Striking Down False Claims Act’s Qui Tam Statute Tees Up Further Litigation Over Whistleblower Lawsuits

Perkins Coie on

A recent Florida district court decision declared that the False Claims Act’s (FCA) qui tam provision violates the Constitution by vesting executive power in private whistleblowers (relators) that have not been appointed by...more

Akerman LLP - Health Law Rx

Zafirov Decision Sets Stage for Appellate Showdown Over Constitutionality of FCA’s Qui Tam Provision

For the first time ever, a judge has ruled that the qui tam provision of the False Claims Act (FCA), which whistleblowers have used to recover $52 billion on behalf of the government since 1986, is unconstitutional....more

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