News & Analysis as of

Relators False Claims Act (FCA) Corporate Counsel

Lowenstein Sandler LLP

The Future of the False Claims Act

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On May 19, 2025, Deputy Attorney General Todd Blanche issued a memorandum titled Civil Rights Fraud Initiative announcing the Department of Justice’s (DOJ) plan to use the False Claims Act (FCA) to “aggressively” pursue...more

DLA Piper

Federal Judge Rules Whistleblower Provision of the False Claims Act is Unconstitutional

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In an eye-opening decision, a judge in the Middle District of Florida held that the unique whistleblower, or “qui tam,” provision of the federal False Claims Act (FCA) violates the Appointments Clause of Article II of the...more

Bass, Berry & Sims PLC

Novel Ruling Raises Questions About Timing of Constitutional Challenges to the FCA’s Qui Tam Provisions

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In recent months, False Claims Act (FCA) defendants have increasingly sought to challenge the constitutionality of the statute’s qui tam provisions. This trend gained momentum following Justice Thomas’s dissent in United...more

Jones Day

Supreme Court Increasingly Wading Into False Claims Act's Morass

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In Short - The Situation: The federal False Claims Act ("FCA") allows the United States to dismiss the action if the qui tam relator "has been notified by the Government of the filing of the motion and the court has...more

Sheppard Mullin Richter & Hampton LLP

Supreme Court To Review DOJ’s Authority to Dismiss Qui Tam FCA Suits Over Objections From Relators

On June 21, 2022 the Supreme Court granted certiorari in Polansky v. Exec. Health Res., 17 F.4th 376 (3d Cir. 2021), allowing the Court to review the Department of Justice’s (“DOJ”) authority to dismiss qui tam suits brought...more

McGuireWoods LLP

Sixth Circuit Creates Circuit Split, Allows Former Employee’s FCA Retaliation Claim

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The U.S. Court of Appeals for the Sixth Circuit held, in connection with an interlocutory appeal, that the False Claims Act (FCA) anti-retaliation provisions protect relators from post-employment retaliatory conduct. In...more

Troutman Pepper Locke

The “New” Enforcers: How States and Localities Are Changing the Landscape of Regulatory Authority

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Over the last decade, observers have noted that states have begun to play a greater role as regulatory enforcers – a trend that increased with the federal regulatory roll-back that began with the advent of the Trump...more

McGuireWoods LLP

3rd Circuit Case of First Impression Clarifies Lower Threshold for FCA Actions

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Government contractors should take note of a March 4, 2020, ruling by the 3rd U.S. Circuit Court of Appeals (Court) that lowers the jurisdictional threshold for establishing a claim under the False Claims Act (FCA)....more

American Conference Institute (ACI)

[Event] False Claims and Qui Tam Enforcement Forum – Strategies to Respond to the Rapidly Changing Landscape of False Claims Act...

With more than 34.8 billion recovered by the government since 2010 under the federal False Claims Act, it has never been more crucial for private practitioners and corporate in-house counsel to keep abreast of the changes and...more

Bradley Arant Boult Cummings LLP

Cybersecurity Violations Potentially Actionable under the False Claims Act

A California federal court recently allowed a relator’s False Claims Act suit against two federal contractors to proceed where the relator’s allegations centered on purported noncompliance with federal cybersecurity...more

Bass, Berry & Sims PLC

Relax, Sixth Circuit Opinion Indicates Rule 9(b) Pleading Requirement Still Has Bite

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A recent Sixth Circuit opinion in U.S. ex rel. Hirt v. Walgreen Co. should come as welcome news for FCA defendants concerned about the implications of the Sixth Circuit’s application last year, for the first time, of a...more

Bass, Berry & Sims PLC

Seventh Circuit Revisits Sanford-Brown, Rejects Implied Certification Claim

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In one of the few cases to apply the Supreme Court’s recent decision in Universal Health Services v. Escobar, the Seventh Circuit recently revisited and affirmed its prior rejection of an implied certification claim under the...more

Dorsey & Whitney LLP

D.C. Circuit Upholds Public-Disclosure-Bar Dismissal Based On Information Posted to Websites

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Last week, the U.S. Court of Appeals for the D.C. Circuit upheld a district court’s dismissal of a qui tam action under the oft-litigated, “public disclosure bar,” where the transactions that gave rise to an inference of...more

Dorsey & Whitney LLP

District Court Rejects “Worthless Services” FCA Claim, Interprets First-to File Bar and Res Judicata in FCA Context

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Earlier this month, the U.S. District Court for the Eastern District of Virginia dismissed a 2-count False Claims Act (FCA) complaint against Unisys Corporation. United States ex rel. Soodavar v. Unisys Corp., 2016 WL 1367163...more

Bryan Cave Leighton Paisner

If Uncle Sam Knows, Doesn’t Everyone? Seventh Circuit Affirms Dismissal Under Public Disclosure Bar, But Opens Door for...

On Feb. 29, the Seventh Circuit affirmed the dismissal of a False Claims Act (FCA) suit, holding the relator, Cause of Action, failed to establish subject matter jurisdiction given the FCA’s public disclosure bar (Cause of...more

Troutman Pepper

A Case to Watch: Highway Contractor Appeals $663M False Claims Act Judgment

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On August 31, 2015, highway contractors Trinity Industries, Inc. and Trinity Highway Products, LLC (collectively, Trinity) appealed to the U.S. Court of Appeals for the Fifth Circuit a $663,360,750 final judgment entered...more

Mintz - Health Care Viewpoints

Trinity Homecare Settlement: Five False Claims Trends

New York State Attorney General Eric Schneiderman recently announced that his office had reached a $2.5 million settlement in a federal False Claims Act (FCA) case with Trinity HomeCare and its related entities. The case,...more

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