On June 25, 2020, the United States Court of Appeals for the Eleventh Circuit reversed one of the most noted False Claims Act (FCA) decisions to have been handed down in a decade and reinstated most of a 2017 jury verdict holding owners and operators of skilled nursing facilities liable for damages and penalties under the FCA. While applying the same “rigorous” post-Escobar materiality and knowledge standards that led the trial judge to find the trial record showed “an entire absence of evidence” of materiality, the appellate court found that “plain and obvious” evidence of materiality supported a verdict of $85 million in single damages for Medicare fraud. But in affirming the trial court’s rejection of the jury’s verdict finding fraud on the Florida Medicaid program, the panel also showed that Escobar materiality can meaningfully limit the reach of the FCA in the right circumstances.