News & Analysis as of

Article II

Baker Donelson

Biding Time: SCOTUS Denies Cert in Lilly, but the Constitutional Threat to FCA Relators May Only Be Getting Closer

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The Supreme Court of the United States (SCOTUS) denied Eli Lilly and Company's petition for certiorari in U.S. ex rel. Streck v. Eli Lilly on May 18, 2026, leaving intact an approximately $220 million False Claims Act (FCA)...more

Bradley Arant Boult Cummings LLP

The Third Circuit Joins the FCA Constitutionality Debate

The Third Circuit recently heard oral argument on the ongoing question regarding the constitutionality of the qui tam provision of the False Claims Act (FCA)....more

Shumaker, Loop & Kendrick, LLP

Client Alert: FINRA Under Fire: New Lawsuit Challenges the Constitutionality of Its Enforcement Power

The Financial Industry Regulatory Authority's (FINRA) enforcement framework is again under scrutiny, as Boustead Securities, Sutter Securities, and former CEO Keith Moore filed a constitutional challenge in the U.S. District...more

Dinsmore & Shohl LLP

NLRB Attempts to Sever Constitutionally Challenged Member Protections

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The National Labor Relations Board (“NLRB”) recently asked the United States District Court for the Southern District of Texas to issue a declaratory judgment severing the statutory removal protections for NLRB board members...more

Sheppard

Expanding, Yet Under Fire: Takeaways on The False Claims Act in 2026 from the ABA White Collar Crime Institute

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The FCA Panel at the 2026 ABA White Collar Crime Institute in San Diego made one thing clear: the False Claims Act is in a constant flux, shaped by constitutional tensions, policy debates, and a rapidly politicizing...more

Morgan Lewis

Third Circuit Considers Constitutionality of False Claims Act Qui Tam Provisions

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A US Court of Appeals for the Third Circuit panel heard oral argument on March 18, 2026 in an appeal of a 2025 District of New Jersey decision upholding a jury verdict in favor of qui tam relators, presenting an opportunity...more

Pietragallo Gordon Alfano Bosick & Raspanti,...

History is History – Qui Tam Provisions No FCA Mystery

Judge Kenney of the Eastern District of Pennsylvania, in Jonathan Meyer v ADS Clinics, LLC, No. 21-cv-5303, on February 10, 2026, rejected a most recent attempt to gut the qui tam provisions from the federal False Claims Act...more

Holland & Knight LLP

Government Contracts Enforcement: DOJ Publishes Fiscal Year 2025 False Claims Act Statistics

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The U.S. Department of Justice (DOJ) has published its statistics on False Claims Act (FCA) settlements and judgments for fiscal year (FY) 2025, revealing an unprecedented, record-breaking year for enforcement. According to...more

Baker Botts L.L.P.

Inside the DOJ’s New AI Litigation Task Force

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On January 9, 2026, the United States Department of Justice (“DOJ”) announced the creation of an Artificial Intelligence Litigation Task Force (“Task Force”) through an internal memorandum....more

Mintz - Health Care Viewpoints

Qui Tam Quandaries: False Claims Act at a Constitutional Crossroads — EnforceMintz

Explore key constitutional False Claims Act (FCA) issues, including Article II and Excessive Fines Clause challenges. Learn how recent court decisions impact FCA enforcement and penalty limits in 2026....more

Akerman LLP - Health Law Rx

The Zafirov Appellate Argument — Panel Steers Parties to Address Whistleblower Control

The much-anticipated appellate showdown regarding the constitutionality of the whistleblower (or qui tam) provision of the federal False Claims Act (FCA) took place before a three-judge panel of the Eleventh Circuit Court of...more

Nelson Mullins Riley & Scarborough LLP

FTC Administrative Action Delayed as Dealer Group Presses for Reconsideration of Order Denying Constitutional Challenge

After a delay caused by the shutdown of the federal government last fall, Asbury Automotive Group (“Asbury”), one of the largest automobile dealer groups in the country, has resumed its constitutional challenge to the...more

King & Spalding

Eleventh Circuit Hears Oral Argument on Constitutionality of the False Claims Act’s Qui Tam Provision

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On December 12, 2025, the U.S. Court of Appeals for the Eleventh Circuit heard argument in United States ex rel. Zafirov v. Florida Medical Association, LLC (Zafirov), which involves a challenge to the constitutionality of...more

Epstein Becker & Green

Supreme Court Sides Against Trump Administration on National Guard Deployment - SCOTUS Today

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The SCOTUS Today series doesn’t usually report on U.S. Supreme Court opinions relating to its interim orders, e.g., orders dealing with stays....more

Dorsey & Whitney LLP

FCA Basics: Qui Tam Lawsuits

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This is the third post in the Dorsey FCANow Blog’s FCA Basics Series covering the fundamentals of the False Claims Act (“FCA”), outlining FCA procedure, and highlighting key facets of FCA practice. Today’s post introduces the...more

Phelps Dunbar

Does the False Claims Act’s Whistleblower Provision Violate the Constitution? Oral Argument on U.S. ex rel Zafirov v. Florida...

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On a path that likely leads to the U.S. Supreme Court, the Eleventh Circuit Court of Appeals held oral argument last week in United States ex rel Zafirov v. Florida Medical Associates, LLC, et al. Judges Elizabeth L. Branch,...more

Polsinelli

FCA at a Crossroads: Eleventh Circuit Case Could Upend Qui Tam Actions

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Key Takeaways: Eleventh Circuit Hears Landmark Qui Tam Appeal: The Eleventh Circuit heard oral argument in United States ex rel. Zafirov, an appeal from a district court decision holding the FCA’s qui tam provisions...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

D.C. Circuit Decision Holding That MSPB Members Are Subject to At-Will Removal May Impact OSHRC

The U.S. Court of Appeals for the District of Columbia Circuit’s recent consolidated decision in Harris v. Bessent and Wilcox v. Trump, holding that members of the Merit Systems Protection Board (MSPB) and National Labor...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

D.C. Circuit Upholds Presidential Power to Remove NLRB and MSPB Members Without Cause

On December 5, 2025, the U.S. Court of Appeals for the District of Columbia Circuit upheld President Donald Trump’s removal of former National Labor Relations Board (NLRB) member Gwynne Wilcox and former Merit Systems...more

ArentFox Schiff

Eleventh Circuit Actively Engaged on Question of FCA’s Qui Tam Provisions’ Constitutionality

ArentFox Schiff on

On December 12, the Eleventh Circuit heard the much-anticipated oral arguments in United States ex rel. Zafirov v. Florida Medical Associates LLC concerning the constitutionality of the False Claims Act’s (FCA) qui tam...more

Bradley Arant Boult Cummings LLP

11th Circuit Oral Argument Focuses on History While Considering the FCA’s Constitutionality

On Friday, the Eleventh Circuit heard oral arguments in United States ex rel. Zafirov v. Florida Medical Associates, LLC regarding the constitutionality of the qui tam provisions in the False Claims Act, which allow private...more

Ropes & Gray LLP

The Eleventh Circuit Questions the Constitutionality of FCA’s Qui Tam Provision

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Friday, the Eleventh Circuit heard oral argument in a closely watched appeal concerning whether the qui tam provisions of the False Claims Act (“FCA”) are constitutional....more

Sheppard

Eleventh Circuit Hears Oral Arguments in High-Profile Challenge to Constitutionality of The False Claim Act’s Qui Tam Provision

Sheppard on

The Eleventh Circuit heard oral argument in United States ex rel. Zafirov v. Florida Medical Associates, LLC, a case addressing the constitutionality of qui tam relators that has drawn national attention. At stake is the...more

Foley & Lardner LLP

Eleventh Circuit Hears Oral Argument in Landmark Constitutional Challenge to False Claims Act’s Qui Tam Provisions

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On December 12, the U.S. Court of Appeals for the Eleventh Circuit heard oral argument in U.S. ex rel. Zafirov v. Florida Medical Associates, a closely watched appeal arising from Foley’s precedent-setting victory for its...more

Epstein Becker & Green

Eleventh Circuit to Weigh the Constitutionality of the False Claims Act’s Qui Tam Provisions

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On December 12, 2025, the U.S. Court of Appeals for the Eleventh Circuit is scheduled to hear oral arguments in Zafirov v. Florida Medical Associates LLC, No. 24-13581, a case that squarely presents the question of the...more

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