News & Analysis as of

Take Care Clause

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

Polsinelli

Sixth Circuit Holds the Line on FCA Qui Tam Challenges as Eleventh Circuit Looms

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Key Takeaways: Sixth Circuit FCA precedent remains intact. The Sixth Circuit declined to entertain constitutional challenges to the FCA’s qui tam provisions, emphasizing that binding circuit precedent forecloses arguments...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

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

Dorsey & Whitney LLP

The Eleventh Circuit Hears Oral Argument in Zafirov: The Case that Could Upend Qui Tam Litigation

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On December 12, 2025, the Eleventh Circuit heard oral arguments in United States ex rel. Zafirov v. Florida Medical Associates, an appeal challenging relators’ authority to bring claims under the qui tam provisions of the...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

ArentFox Schiff

Zafirov One Year Later: Constitutional Challenges to the False Claims Act’s Qui Tam Provision

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Judge Kathryn Kimball Mizelle’s ground-breaking decision in Zafirov v. Florida Medical Associates LLC and Justice Clarence Thomas’ solo dissent in US ex rel. Polansky v. Executive Health Resources Inc. have revived what many...more

Phelps Dunbar

The Constitutional Battle Over False Claims Act Qui Tams and Founding Era History in Zafirov

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Last fall, U.S. District Court Judge Kathryn Mizelle of the Middle District of Florida ruled that the False Claims Act’s (FCA) qui tam provision is unconstitutional in United States ex rel Zafirov v. Florida Medical...more

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

Federal Court Ruling in Texas Challenges OSHA’s Administrative Law Judge System

In May 2023, in the wake of a ruling by the Supreme Court of the United States that U.S. district courts have jurisdiction to consider structural constitutional claims against administrative agencies, we predicted that the...more

King & Spalding

United States District Court in Florida Holds False Claims Act Qui Tam Provision Unconstitutional

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On September 30, 2024, a federal district court in Florida held the qui tam enforcement provision of the False Claims Act (“FCA”), which permits private citizens to pursue actions in the name of and on behalf of the...more

Husch Blackwell LLP

Florida Federal Court Strikes Down False Claims Act Qui Tam Provisions as Unconstitutional

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A federal judge in Florida issued a ruling this week holding that the qui tam provisions of the False Claims Act (FCA) are unconstitutional. In the lawsuit, a relator named Clarissa Zafirov accused the defendants of violating...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

Zuckerman Spaeder LLP

Under “Damocles’ Sword”: Considering Removal Protections and the Take Care Clause in Light of SEC v. Jarkesy

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The Constitution requires judicial independence in Article III. As Hamilton observed in “Federalist 78”: “The standard of good behavior for the continuance in office of the judicial magistracy . . . . is the best expedient...more

Mintz - Health Care Viewpoints

Challenge to False Claims Act Qui Tam Provisions Fails in an Initial Attempt to Revive Long-Dormant Arguments as to...

This July, we detailed the Supreme Court’s surprising revival in United States ex rel. Polansky v. Exec. Health Resources, No. 21-1052 (S. Ct. June 16, 2023) of the question of whether the qui tam provisions of the False...more

Husch Blackwell LLP

The Justice Insiders: The Administrative State is Not Your Friend - A Conversation with Professor Richard Epstein

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In this episode of The Justice Insiders, we welcome Richard A. Epstein, Laurence A. Tisch Professor of Law at NYU School of Law. Host Gregg Sofer and co-host Steve Renau explore with Professor Epstein the implications...more

Robinson & Cole LLP

Fifth Circuit Decision Threatens to Upend SEC’s Use of Administrative Proceedings

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In a landmark decision, the Fifth Circuit struck down the U.S. Securities and Exchange Commission’s (SEC) primary mechanism for enforcing the nation’s securities laws. In Jarkesy v. Securities and Exchange Commission, a...more

Troutman Pepper Locke

Recent Decisions Cast Shadow Over SEC’s In-House Adjudication System

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Two recent judicial developments create questions about the constitutionality of the SEC’s in-house judicial system. First, on May 16, the Supreme Court agreed to hear the case of Michelle Cochran, an accountant facing...more

Skadden, Arps, Slate, Meagher & Flom LLP

Fifth Circuit Holds SEC Proceeding Brought in Agency’s In-House Court Unconstitutional

Key Points On May 18, 2022, in Jarkesy v. SEC, No. 20-61007 (5th Cir. May 18, 2022), a split panel of the U.S. Court of Appeals for the Fifth Circuit identified three independent constitutional flaws in the administrative...more

Vinson & Elkins LLP

Fifth Circuit Issues a New Blow to SEC Administrative Law Judges

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On May 18, 2022, the Fifth Circuit issued an opinion vacating a Securities and Exchange Commission (“SEC”) Administrative Law Judge’s (“ALJ”) decision that George Jarkesy, Jr. (“Jarkesy”) and his investment adviser Patriot28,...more

Sheppard

Federal Court Decides ACA “Sabotage” Case

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On March 4th, the U.S. District Court for the District of Maryland struck down four provisions of the Trump Administration’s Notice of Benefit and Payment Parameters for 2019, 83 Fed. Reg. 16930 (April 17, 2018) (the “Rule”),...more

McGuireWoods Consulting

The Courts and Healthcare Policy

2020 saw the courts continuing to play an important role in health policy with several notable lawsuits related to the Affordable Care Act (ACA). Several other Trump administration policies were challenged, including Medicare...more

Ballard Spahr LLP

CFPB files amicus brief in Third Circuit supporting PA AG

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The CFPB has filed an amicus brief in the U.S. Court of Appeals for the Third Circuit in the Pennsylvania Attorney General’s lawsuit against Navient Corp.  The PA AG’s lawsuit includes claims that Navient violated the...more

Sheppard

Arkansas and Kentucky Halt Medicaid Work Requirements

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On April 10, 2019, the Department of Justice filed notices appealing two District Court rulings that struck down Medicaid work requirements in both Kentucky and Arkansas to the U.S. Court of Appeals for the District of...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Border-Wall: Environmental Groups File U.S. District Court (District of Columbia) Action Against Department of Homeland Security...

The Center for Biological Diversity, Defenders of Wildlife, and Animal Legal Defense Fund (collectively “CBD”) filed an October 17th Complaint for Declaratory and Injunctive Relief (“Complaint”) challenging the issuance of...more

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