False Claims Act Year in Review by HaynesBoone Law Firm


The False Claims Act, 31 U.S.C. §§ 3729, et seq. (FCA) continued to be a significant focus of government and whistleblower activity in 2016. This Year in Review highlights several key developments, including:

  • The U.S. Department of Justice is continuing its strong enforcement of the FCA, including recovering more than $4.7 billion in settlements and judgments in FCA cases in 2016, as well as continuing its focus on individual culpability.
  • The number of FCA lawsuits filed by whistleblowers in 2016 climbed back above 700.
  • The U.S. Supreme Court clarified the so-called “implied certification” theory of liability and resolved a circuit split on violations of the FCA seal requirements.
  • Lower courts continue interpreting the pleading requirements for FCA claims, analyzing the public disclosure bar, and addressing relators’ rights and obligations, among other issues.

Download the False Claims Act: 2016 Year in Review.



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