News & Analysis as of

Take Care Clause Article II

Phelps Dunbar

The Constitutional Battle Over False Claims Act Qui Tams and Founding Era History in Zafirov

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Last fall, U.S. District Court Judge Kathryn Mizelle of the Middle District of Florida ruled that the False Claims Act’s (FCA) qui tam provision is unconstitutional in United States ex rel Zafirov v. Florida Medical...more

King & Spalding

United States District Court in Florida Holds False Claims Act Qui Tam Provision Unconstitutional

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On September 30, 2024, a federal district court in Florida held the qui tam enforcement provision of the False Claims Act (“FCA”), which permits private citizens to pursue actions in the name of and on behalf of the...more

Husch Blackwell LLP

Florida Federal Court Strikes Down False Claims Act Qui Tam Provisions as Unconstitutional

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A federal judge in Florida issued a ruling this week holding that the qui tam provisions of the False Claims Act (FCA) are unconstitutional. In the lawsuit, a relator named Clarissa Zafirov accused the defendants of violating...more

Robinson+Cole Health Law Diagnosis

Middle District of Florida Judge Finds False Claims Act’s Qui Tam Provision Unconstitutional

On September 30, 2024, Judge Kathryn Kimball Mizelle of the U.S. District Court for the Middle District of Florida issued an order in United States ex rel. Clarissa Zafirov v. Florida Medical Associates, LLC, holding that the...more

Mintz - Health Care Viewpoints

Challenge to False Claims Act Qui Tam Provisions Fails in an Initial Attempt to Revive Long-Dormant Arguments as to...

This July, we detailed the Supreme Court’s surprising revival in United States ex rel. Polansky v. Exec. Health Resources, No. 21-1052 (S. Ct. June 16, 2023) of the question of whether the qui tam provisions of the False...more

Robinson & Cole LLP

Fifth Circuit Decision Threatens to Upend SEC’s Use of Administrative Proceedings

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In a landmark decision, the Fifth Circuit struck down the U.S. Securities and Exchange Commission’s (SEC) primary mechanism for enforcing the nation’s securities laws. In Jarkesy v. Securities and Exchange Commission, a...more

Troutman Pepper Locke

Recent Decisions Cast Shadow Over SEC’s In-House Adjudication System

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Two recent judicial developments create questions about the constitutionality of the SEC’s in-house judicial system. First, on May 16, the Supreme Court agreed to hear the case of Michelle Cochran, an accountant facing...more

Skadden, Arps, Slate, Meagher & Flom LLP

Fifth Circuit Holds SEC Proceeding Brought in Agency’s In-House Court Unconstitutional

Key Points On May 18, 2022, in Jarkesy v. SEC, No. 20-61007 (5th Cir. May 18, 2022), a split panel of the U.S. Court of Appeals for the Fifth Circuit identified three independent constitutional flaws in the administrative...more

Vinson & Elkins LLP

Fifth Circuit Issues a New Blow to SEC Administrative Law Judges

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On May 18, 2022, the Fifth Circuit issued an opinion vacating a Securities and Exchange Commission (“SEC”) Administrative Law Judge’s (“ALJ”) decision that George Jarkesy, Jr. (“Jarkesy”) and his investment adviser Patriot28,...more

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