News & Analysis as of

Constitutional Challenges Appointments Clause

McGuireWoods LLP

Fifth Circuit Concurrence Adds Voice to FCA Constitutionality Questions

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A first appellate circuit judge has questioned the False Claim Act’s constitutionality. In the Fifth Circuit’s decision last month in United States ex rel Montcrief v. Peripheral Vascular Assocs., P.A., No. 24-50176, — F....more

McDermott Will & Emery

An Odyssey of Timeliness: Appointments Clause Arguments Must Be Preserved

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Citing forfeiture, the US Court of Appeals for the Federal Circuit upheld the dismissal of a complaint against the US Patent & Trademark Office (PTO). The complaint sought director review of a 2018 Patent Trial & Appeal Board...more

Cozen O'Connor

Democratic AGs File Lawsuit Asking Court to Muzzle DOGE

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A group of 14 Democratic AGs filed a lawsuit in federal court challenging the delegation of executive authority to the Department of Government Efficiency (DOGE). The lawsuit alleges that DOGE violates separation of powers...more

Miller Canfield

Is the Chief of IRS Appeals Constitutionally Appointed?

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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

Orrick, Herrington & Sutcliffe LLP

Fourteen state attorneys general sue Trump Administration, Elon Musk, challenging constitutionality of DOGE authority

On February 13, fourteen state attorneys general (AGs) filed a complaint in the U.S. District Court for the District of Columbia challenging the authority of DOGE and its head, Elon Musk, to take actions across the federal...more

Groom Law Group, Chartered

Supreme Court to Decide Legality of ACA’s Preventive Services Mandate

On January 10, 2025, the Supreme Court agreed to hear an appeal in Becerra v. Braidwood Management, Inc. (“Braidwood”). The case (discussed in a prior Groom alert), on appeal from the Fifth Circuit, will determine if the...more

Husch Blackwell LLP

Are the qui tam provisions of the False Claims Act unconstitutional?

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The qui tam provisions of the False Claims Act allow individuals to file suit on behalf of the United States and to receive a share of the resulting financial settlement or judgment. Filing a qui tam case is not just a formal...more

Akerman LLP - Health Law Rx

Update: Appellate Showdown Over FCA Qui Tam Provision’s Constitutionality Reaches Eleventh Circuit

As we anticipated in our October 17, 2024, blog, both the Government and the Relator have appealed the district court’s decision in U.S. ex rel. Zafirov v. Florida Medical Associates, LLC, et al. (Zafirov), the first case to...more

ArentFox Schiff

Investigations Newsletter: Federal Government Urges Court of Appeals to Uphold Constitutionality of FCA Qui Tam Provisions

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Federal Government Urges Court of Appeals to Uphold Constitutionality of FCA Qui Tam Provisions - In a brief filed earlier this week, the US federal government has urged the Eleventh Circuit Court of Appeals to uphold the...more

Orrick, Herrington & Sutcliffe LLP

The False Claims Act: How a Recent Decision Rejecting Qui Tam Lawsuits May Affect Enforcement

For over 160 years, the False Claims Act has let people bring claims on behalf of the U.S. government alleging fraud. In exchange, those individuals receive a portion of any recovery. In September, a federal district judge...more

Morgan Lewis

DC Circuit Sidesteps Questions Around FINRA’s Constitutionality

Morgan Lewis on

On November 22, 2024, the US Court of Appeals for the DC Circuit issued its decision in the closely watched Alpine Securities Corp. v. FINRA case. Declining to decide larger constitutional questions, the court instead...more

Kilpatrick

The End of Qui Tam FCA Claims? How a Federal District Judge Might Have Just Sounded the Death Knell For Whistleblower Lawsuits

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A seismic shift in the world of False Claims Act (“FCA”) might have occurred recently in a Middle District of Florida courtroom. On September 30, 2024, Judge Kathryn Kimball Mizelle issued her ruling in US ex rel Zafirov v....more

Seyfarth Shaw LLP

Federal District Court Finds False Claims Act Qui Tam Provision Unconstitutional

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In a landmark decision, the United States District Court for the Middle District of Florida, in United States ex rel. Zafirov v. Florida Medical Associates, LLC, held that the False Claims Act’s (FCA) qui tam provision –...more

Perkins Coie

Novel Decision Striking Down False Claims Act’s Qui Tam Statute Tees Up Further Litigation Over Whistleblower Lawsuits

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A recent Florida district court decision declared that the False Claims Act’s (FCA) qui tam provision violates the Constitution by vesting executive power in private whistleblowers (relators) that have not been appointed by...more

Clark Hill PLC

Florida Federal Court Declares the FCA’s Qui Tam Relator Appointments Unconstitutional

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On Sept. 30, the U.S. District Court for the Middle District of Florida declared the qui tam provisions of the federal False Claims Act unconstitutional. The Court, in United States Of America ex rel Clarissa Zafirov v....more

Genova Burns LLC

10th Birthday Wishes to the Affordable Care Act’s Employer Mandate

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The Patient Protection and Affordable Care Act (“ACA”) was signed into law by President Obama on March 23, 2010. ACA affected health insurance coverage, costs and preventive care. It also established the Health Insurance...more

Baker Donelson

Zafirov Decision: A Turning Point or Just Another Chapter in Qui Tam?

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A tool long-favored by the plaintiffs' bar to extract big judgments and settlements from individuals and companies – the False Claims Act (FCA) – which allows individual whistleblowers to pursue alleged civil wrongdoers in...more

Troutman Pepper Locke

The Beginning of the End for False Claims Act Qui Tam Cases? Florida District Judge Holds Whistleblower Provisions...

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On September 30, 2024, Judge Kathryn Kimball Mizelle held that the qui tam provision of the FCA violates the Appointments Clause of the United States Constitution because False Claims Act (“FCA”) relators are acting as...more

K&L Gates LLP

Is It the End of the False Claims Act As We Know It? District Court Rules Qui Tam Provisions Unconstitutional

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In a first-of-its-kind ruling on 30 September 2024, Judge Kathryn Kimball Mizelle of the US District Court for the Middle District of Florida held in United States ex rel. Zafirov v. Florida Med. Assocs., LLC that the qui tam...more

Arnall Golden Gregory LLP

Outlier or Harbinger: District Court Declares FCA Qui Tam Provisions Unconstitutional

The federal False Claims Act (“FCA”) is the United States’ primary civil tool for prosecuting fraud against the government. It was enacted in 1863 during the Civil War and, from its inception, has included qui tam provisions...more

DLA Piper

Federal Judge Rules Whistleblower Provision of the False Claims Act is Unconstitutional

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In an eye-opening decision, a judge in the Middle District of Florida held that the unique whistleblower, or “qui tam,” provision of the federal False Claims Act (FCA) violates the Appointments Clause of Article II of the...more

Latham & Watkins LLP

Middle District of Florida Accepts Justice Thomas’s Invitation: FCA Qui Tam Provision Unconstitutional

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The Zafirov decision finds that the False Claims Act qui tam provision violates Article II of the US Constitution. On September 30, 2024, in United States ex rel. Zafirov v. Florida Medical Associates LLC, Judge Kathryn...more

Troutman Pepper Locke

The Beginning of the End for False Claims Act Qui Tam Cases? Florida District Judge Holds Whistleblower Provisions...

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On September 30, Judge Kathryn Kimball Mizelle held that the qui tam provision of the False Claims Act (FCA) violates the Appointments Clause of the U.S. Constitution because FCA relators are acting as “officers of the U.S.”...more

Robinson+Cole Health Law Diagnosis

Middle District of Florida Judge Finds False Claims Act’s Qui Tam Provision Unconstitutional

On September 30, 2024, Judge Kathryn Kimball Mizelle of the U.S. District Court for the Middle District of Florida issued an order in United States ex rel. Clarissa Zafirov v. Florida Medical Associates, LLC, holding that the...more

Ballard Spahr LLP

Florida Federal Court Holds False Claims Act Qui Tam Provision Violates Article II

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A federal court in Florida this week ruled that the qui tam provision of the False Claims Act (FCA) is unconstitutional under the Appointments Clause in Article II of the U.S. Constitution, creating an opportunity for a split...more

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