Participants in federal programs take note: the government’s specific representations that a program is compliant may help insulate you from False Claims Act liability. But, be wary of general guidance, which may not offer you the same protection.
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Recent Posts
Blog Post
06/26/2019
Blog Post
05/17/2019
Recently, Judge Timothy J. Savage of the U.S. District Court for the Eastern District of Pennsylvania said the government cannot simply exercise “unfettered discretion” to dismiss a qui tam action.
Blog Post
02/04/2019
On January 7, 2019, the New York State Department of Financial Services (the “Department”) published Guidance on Whistleblowing Programs (the “Guidance”).
Blog Post
01/02/2019
On October 29, 2018, a three-judge panel in New Jersey’s Superior Court held the lower court improperly expanded a confidentiality provision in a deal among four relators.
Blog Post
12/18/2018
The U.S. Supreme Court recently granted cert to resolve a circuit split deepened by the Eleventh Circuit’s holding that the statute of limitations period for False Claims Act (FCA) suits runs from the date the government first learns of the alleged violations, whether or not the government intervenes.
Blog Post
10/18/2018
On September 4, 2018, the Third Circuit revived a False Claims Act (FCA) suit against PharMerica Corporation that the District Court had dismissed based on the FCA’s public disclosure bar.
Blog Post
10/08/2018
In August 2018, the U.S. Court of Appeals for the Second Circuit held that a violation of the False Claims Act (FCA) first-to-file bar cannot be cured by filing an amended complaint after the first-filed related action is no longer pending.
Blog Post
09/06/2018
This summer the Commodity Futures Trading Commission (“CFTC”) issued its first award since August 2016. On July 12, 2018, the CFTC announced a $30 million award, which was only the fifth award under the CFTC’s whistleblower program and the largest since the program’s creation in 2011.
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