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But For Causation

Husch Blackwell LLP

False Claims Act Insights - Emptying Our FCA Notebook: A Summary of Recent FCA-Related Developments

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Host Jonathan Porter welcomes back to the show Husch Blackwell litigator Tanner Cook to discuss an assortment of recent False Claims Act-related legal and policy developments. A U.S. Supreme Court FCA decision, a rare FCA...more

McCarter & English, LLP

Federal Courts Decide on FCA Claims Actions

There are still several unsettled legal issues regarding the standards applicable to a False Claims Act (FCA) claim, such as the standard to prove causation when an FCA claim is based on a violation of the Anti-Kickback...more

Latham & Watkins LLP

First Circuit Reins In Broad Theory of Liability Under AntiKickback Statute by Adopting “But-For Causation” Standard

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The First Circuit joins the Sixth and Eighth Circuits in adopting a more exacting causation standard for False Claims Act liability premised on Anti-Kickback Statute violations. In a victory for False Claims Act (FCA)...more

Harris Beach Murtha PLLC

First Circuit Decision Raises Bar on Anti-Kickback Statute-Premised Liability Under the False Claims Act

The United States Court of Appeals for the First Circuit recently joined the Sixth Circuit (2023) and Eighth Circuit (2022) in holding that the term “resulting from” in the Federal Anti-Kickback Statute (“AKS”) (as amended in...more

Davis Wright Tremaine LLP

In Key Ruling, 1st Circuit Adopts "But-For" Causation Standard for FCA Claims Arising From Unlawful Kickbacks

On February 18, 2025, the U.S. Court of Appeals for the 1st Circuit issued a highly anticipated ruling interpreting the relationship between the False Claims Act ("FCA") and the federal Anti-Kickback Statute ("AKS"), holding...more

WilmerHale

First Circuit Adopts “But For” Causation Standard under the Anti-Kickback Statute, Paving the Way for Potential Supreme Court...

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Last week, the First Circuit Court of Appeals issued its long-awaited decision in United States v. Regeneron Pharmaceuticals with significant implications for health care companies facing allegations of violations of the...more

ArentFox Schiff

Investigations Newsletter: First Circuit Joins Sixth and Eighth Circuits in Adopting Heightened, But-For Causation Standard for...

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First Circuit Joins Sixth and Eighth Circuits in Adopting Heightened, But-For Causation Standard for AKS-Based FCA Claims - On February 18, the US Court of Appeals for the First Circuit became the latest court to agree...more

Bass, Berry & Sims PLC

First Circuit Adopts “But-For” Causation Standard for Proving Kickback FCA Violations

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In a closely watched appeal, the U.S. Court of Appeals for the First Circuit ruled on February 18 that to satisfy the causation requirement in False Claims Act (FCA) actions based on alleged Anti-Kickback Statute (AKS)...more

Goodwin

First Circuit Adopts Defense-Friendly “But-For” Causation Standard for AKS-Predicated FCA Claims

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In a unanimous panel opinion filed on February 18, 2025, the First Circuit held that False Claims Act cases predicated on violations of the Anti-Kickback Statute (“AKS”), require proof that alleged kickbacks were the...more

Proskauer - Health Care Law Brief

Fault Lines Expected to Deepen: Major False Claims Act Circuit Split

The health care industry is anxiously awaiting the First Circuit’s ruling on the standard of causation for actions brought under the False Claims Act (FCA) predicated on a federal Anti-Kickback Statute (AKS) violation. The...more

ArentFox Schiff

Investigations Newsletter: FCA Enforcement & Compliance Digest — Summer 2024 False Claims Act Newsletter

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Welcome to the Summer 2024 issue of “FCA Enforcement & Compliance Digest,” our quarterly newsletter in which we compile essential updates on False Claims Act (FCA) enforcement trends, litigation, agency guidance, and...more

Dorsey & Whitney LLP

The False Claims Act and the Anti-Kickback Statute: Causation, Materiality, and the Connection Between the Two

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Violations of the federal Anti-Kickback Statute (the “AKS”) have long served as a basis for liability under the federal False Claims Act (the “FCA”). Recently, however, there has been increasing uncertainty regarding how far...more

Proskauer - Health Care Law Brief

Recent Circuit Litigation Continues to Highlight “But-For” Causation Requirement for the Government to Demonstrate an FCA...

In recent years, a circuit split among the United States Courts of Appeals has emerged over how courts have interpreted the False Claims Act’s (“FCA”) causation element in cases where a violation of the Anti-Kickback Statute...more

Epstein Becker & Green

Eleventh Circuit Ruling on Causation Standard a Win for Employers

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The U.S. Court of Appeals for the Eleventh Circuit recently weighed in on the circuit-splitting debate over the proper causation standard for Family and Medical Leave Act (“FMLA”) retaliation claims. In a win for employers,...more

Benesch

11th Circ. FMLA Ruling Deepens Divide Over Causation

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In a win for employers located in Florida, Georgia and Alabama, the U.S. Court of Appeals for the Eleventh Circuit recently concluded that retaliation claims brought under the Family and Medical Leave Act are subject to a...more

Stevens & Lee

Supreme Court of Pennsylvania Boosts Tax-exempt Bond Financing and Economic Development in the Commonwealth

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On Feb. 21, the Supreme Court of Pennsylvania issued its long-awaited tax-exempt bond financing decision, Ursinus College v. Prevailing Wage Appeals Board (No. 18 MAP 2023). Its opinion is a major victory for Pennsylvania...more

Goodwin

2023 Year in Review: Major U.S. Supreme Court and Appellate Cases

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Welcome to the Major US Supreme Court and Appellate Cases chapter of our annual report Consumer Financial Services 2023 Year in Review. Looking Ahead to 2024 - The Supreme Court continues to take a close look at major...more

Seyfarth Shaw LLP

Eleventh Circuit Holds FMLA Retaliation Requires “But-for” Showing

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Seyfarth Synopsis: The United States Court of Appeals for the Eleventh Circuit affirmed a district court’s decision that “but-for” is the proper causation standard for FMLA retaliation claims addressed within the...more

Proskauer - Law and the Workplace

Eleventh Circuit Deepens Circuit Split Over Causation Standard for FMLA Retaliation Claims

On December 13, 2023, an Eleventh Circuit panel firmly established “but-for” causation as the Circuit’s causation standard for Family and Medical Leave Act (FMLA) retaliation claims. Courts across the nation have adopted...more

Benesch

Eleventh Circuit Endorses Heightened Standard for FMLA Retaliation Claims, Deepening Circuit Divide

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In a win for employers, the Eleventh Circuit Court of Appeals issued a decision on December 13, 2023, which formally adopted the “but for” causation standard for retaliation claims brought under the Family Medical Leave Act...more

Amundsen Davis LLC

The Impact of Indiana’s Restrictions on Physician Non-Compete Agreements

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Recent Indiana legislative sessions have limited the ability of health care entities to enter non-compete agreements with physicians, and the impact of that legislation is starting to be seen. By way of background, prior...more

WilmerHale

Government Setback “Resulting From” Another Court Adopting the “But For” Causation Standard for False Claims Act Cases Furthering...

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The U.S. District Court for the District of Massachusetts recently weighed in on the burgeoning court split in False Claims Act (FCA) cases, adopting an approach that puts a higher burden on the government to prove Medicare...more

Stevens & Lee

U.S. Supreme Court Declines to Clarify Key Provisions of the False Claims and Anti-kickback Statutes

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Last week, the U.S. Supreme Court denied the request of qui tam relators that it review the Sixth Circuit’s recent decision in United States of America ex rel. Martin v. Hathaway, No. 22-1463 (6th Cir.). In so doing, the...more

ArentFox Schiff

Investigations Newsletter: Federal Judge Rules Government Must Demonstrate “But-For” Causation for Anti-Kickback Statute Claims

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Federal Judge Rules Government Must Demonstrate “But-For” Causation for Anti-Kickback Statute Claims - On September 27, 2023, Chief Judge Dennis Saylor of the US District Court for the District of Massachusetts ruled that...more

Goodwin

“Greenfield Fraught with Problems”: District of Massachusetts Holds But-For Causation Required in False Claims Act Cases Based on...

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On September 27, 2023, the Chief Judge of the District of Massachusetts decided that the standard in False Claims Act (“FCA”) cases premised on alleged violations of the Anti-Kickback Statute (“AKS”) is but-for causation....more

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