• Escobar’s two-part implied false certification test is mandatory in the 9th Circuit.
• Though couched as adopting the Escobar standard, the 9th Circuit panel’s decision may actually undermine Escobar’s overarching...more
On June 16, 2016, Justice Thomas, writing for a unanimous Court in Universal Health Services, Inc. v. United States ex rel. Escobar,examined the circumstances under which an “implied false certification” can trigger liability...more