News & Analysis as of

Materiality False Claims Act (FCA) Appeals

Miller & Martin PLLC

Fraud in the Inducement: The Collision of Causation, Confusion, Common Law, and Common Sense

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Federal courts have long recognized fraud in the inducement (also referred to as simply “fraudulent inducement”) (“FITI”) as an actionable theory of recovery under the False Claims Act (“FCA”). However, while loosely rooted...more

McDermott Will & Emery

No Loss, No Problem: SCOTUS Expands Wire Fraud Reach in Kousisis Ruling

On May 22, 2025, the Supreme Court of the United States (the Court) issued its opinion in Kousisis v. United States, holding that a defendant may be convicted of wire fraud for inducing a victim to enter a contract under...more

Bradley Arant Boult Cummings LLP

The Haunting in the Cornfield: Relators’ Qui Tam Claim Confirmed Dead by the Eighth Circuit

The Eighth Circuit Court of Appeals recently affirmed judgment against relators in a case alleging that a group of dairy farmers growing corn violated the False Claims Act by filing false insurance claims paid by the Federal...more

Dorsey & Whitney LLP

Eight Years Later: “Speculative” and “Straightforward” FCA Allegations Against Walmart Dismissed

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Walmart successfully ended eight years of protracted litigation under the False Claims Act (“FCA”) on June 4, 2021, when the Sixth Circuit affirmed dismissal of Medicare and Medicaid fraud allegations against the major...more

Bass, Berry & Sims PLC

Eleventh Circuit Broadens Materiality Analysis for Some Cases

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How should a court evaluate the FCA’s materiality requirement when the government’s ability to deny claims is constrained? According to a recent decision from the Eleventh Circuit, the court should “broadly” consider the...more

Dorsey & Whitney LLP

Escobar in Action: Physician-owners’ fraud claims against hospital defeated in Fifth Circuit appeal for lack of materiality

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Following the passage of the Affordable Care Act (“ACA”), which placed new limits on physician-owned hospitals, St. Luke’s Health System (“System”) took action to change one of its hospital’s ownership structures through a...more

Robinson+Cole Health Law Diagnosis

Ninth Circuit Issues Long-Awaited Interpretation of Escobar Two-Part Test

In late August, the U.S. Court of Appeals for the Ninth Circuit issued a long-awaited decision in U.S. ex rel. Rose v. Stephens Institute that interprets key aspects of the implied false certification theory of False Claims...more

Burr & Forman

Escobar Materiality Requirement Wipes Out $347 Million Jury Verdict in False Claims Act Case

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In 2016, the United States Supreme Court issued its decision in Universal Health Servs. v. U.S. ex rel. Escobar which dealt, in part, with how the “materiality” requirement should be enforced in False Claims Act (“FCA”)...more

Bass, Berry & Sims PLC

Fifth Circuit Relies on Escobar in Vacating $663 Million FCA Judgment

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The U.S. Court of Appeals for the Fifth Circuit vacated a $663 million judgment, concluding that the Supreme Court’s opinion in Escobar doomed the plaintiff’s FCA claims on the issue of materiality....more

Bass, Berry & Sims PLC

Fourth Circuit Re-Affirms Sufficiency of Triple Canopy Complaint

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U.S. ex rel. Badr v. Triple Canopy, Inc., an intervened case arising out of the Fourth Circuit, has been one of the more closely-watched recent FCA cases. Previously, the Fourth Circuit held that the government’s complaint...more

Bradley Arant Boult Cummings LLP

False Claims Act: 2016 Year in Review

We are pleased to present Bradley’s annual review of significant False Claims Act (FCA) cases, developments, and trends. From a relatively short article several years ago, the Review has grown to a significant publication...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Escobar and the Implied Certification Theory: Initial Cases Raise the Bar on Materiality in False Claims Act Litigation"

On June 16, 2016, the U.S. Supreme Court in Universal Health Services, Inc. v. United States ex rel. Escobar1 (Escobar) unanimously upheld the implied certification theory of False Claims Act (FCA) liability and strengthened...more

Foley & Lardner LLP

Supreme Court Implied False Certification Case Reargued to First Circuit

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On Tuesday, October 25, 2016, a three-judge panel of the United States Court of Appeals for the First Circuit heard argument in United States ex rel. Escobar, et al. v. Universal Health Services, Inc. This case was sent back...more

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