The United States Tax Court skillfully dodged answering the headline question with a holding on standing. The court decided, however, that IRS appeals officers and IRS appeals team managers are not officers of the United...more
A panel of the D.C. Circuit recently relied on Lucia and Cochran to enjoin a FINRA regulatory enforcement action pending appeal of an Appointments Clause challenge....more
Perhaps the single most appropriate word to describe the current state of the civil and criminal healthcare fraud enforcement environment is uncertainty. From changes in personnel and policy at the highest levels of...more
It doesn’t take much to have “standing to sue” under Article III for a technical violation of FCRA in the 11th Circuit. Based on the 11th Circuit’s October 3, 2018 opinion in Muransky v. Godiva Chocolatier, Inc., 2018 U.S....more