Regulations, Compliance, & Enforcement
Eleventh Circuit Reverses Zafirov, Holding That FCA’s Qui Tam Provisions Are Constitutional Under Appointments Clause
Arent Fox Schiff - The US Court of Appeals for the Eleventh Circuit issued its much-anticipated decision in United States ex rel. Zafirov v....
DOJ’s DEI Enforcement Playbook Continues to Take Shape: What Federal Contractors Need to Know
Womble Bond Dickinson - Last week, the U.S. Department of Justice announced a $21.5 million civil False Claims Act (FCA) settlement with Deloitte concerning...
SCOTUS Next? The Eleventh Circuit’s Zafirov Ruling Delivers a Setback to Defendants But Keeps the False Claims Act Constitutionality Debate Alive
Baker Donelson - The U.S. Court of Appeals for the Eleventh Circuit upheld the constitutionality of the False Claims Act's (FCA) qui tam provision...
AI-Assisted Data Mining and the False Claims Act: Is a Data Anomaly Really a False Claim?
Akerman - Data miner whistleblowers, increasingly armed with artificial intelligence (AI) tools, are already reshaping how False Claims Act (FCA) theories are built, generated,...
Eleventh Circuit Upholds Constitutionality of the False Claims Act’s Qui Tam Provision and Reverses Lower Court
Sheppard Mullin - On September 1, 2026, the Eleventh Circuit upheld the constitutionality of the False Claims Act’s qui tam provision, reversing the lower...
Eleventh Circuit Rejects Appointments Clause Challenge to Qui Tam Mechanism
Sidley - In a landmark decision, the Eleventh Circuit rejected the argument that the FCA’s qui tam mechanism violates the Constitution’s Appointments Clause. The...
Seventh Circuit Outlines Potential Path to Dismissal of Outsiders’ Qui Tam Actions
Skadden - The Seventh Circuit affirmed dismissal of an outsider’s qui tam action under the False Claims Act, outlining a potential path to dismissal...
Eleventh Circuit Rejects One Constitutional Challenge But Leaves Open Questions on FCA Qui Tam Provisions
Morgan Lewis - On September 1, 2026, in a much-anticipated ruling, the Eleventh Circuit vacated a 2024 Middle District of Florida decision ruling that...
DOJ Announces Second DEI-Related False Claims Act Settlement
WilmerHale - On August 25, 2026, the US Department of Justice (DOJ) announced that Deloitte agreed to pay $21.5 million to resolve allegations under...
DOJ Announces Second Settlement Resolving FCA Allegations Based on Employment Discrimination
Sidley - Earlier this week, the Department of Justice (“DOJ”) announced a $21.5 million settlement agreement with five Deloitte entities to resolve allegations that...
Tucson Man Indicted for Lying to Obtain Federal Contract Work While on Active Duty with the Air Force
DOJ - Last week, a federal grand jury in Tucson returned an indictment against Davide Velarde, 44, of Tucson, for making materially false statements...
Deloitte Agrees to Pay $21.5 Million to Resolve Alleged Employment Discrimination Violations
DOJ - Attorney General Todd Blanche announced another False Claims Act resolution secured under the Civil Rights Fraud Initiative, which was launched by the...
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