1. Home
  2. |Insights
  3. |DAM Contractor's Underbidding Insufficient For FCA Liability

DAM Contractor's Underbidding Insufficient For FCA Liability

Client Alert | 1 min read | 01.21.05

Affirming summary judgment, the D.C. Circuit in U.S. ex rel. Bettis v. Oderbrecht Contractors (Jan. 11, 2005) held that evidence that a dam contractor (1) underbid, (2) reaffirmed its underbid, and (3) claimed that it would use cost-saving measures it never employed did not permit the conclusion that the contractor fraudulently induced the Army Corps of Engineers to award it the contract. The Court acknowledged that claims submitted for payment under a contract that was fraudulently induced can give rise to civil False Claims Act liability, but found in this case that the contractor's underbid was not a promise that its estimated costs were accurate, only that it would perform the dam work at the unit prices it bid, such that submission of claims for payment under the contract, including claims for equitable adjustments above the contract price, were not false claims.

Insights

Client Alert | 11 min read | 12.15.25

New York LLC Transparency Act: Key Requirements and Deadlines

On January 1, 2026 (“Effective Date”), the New York LLC Transparency Act ("New York Act”) is scheduled to take effect, introducing new disclosure requirements for limited liability companies (“LLCs”) formed or registered to do business in New York State.  The New York Act is expected to impose the type of broad beneficial ownership requirements the federal CTA and rules implementing it was designed to require, before the federal government’s decision to limit the scope of the CTA’s beneficial ownership reporting requirements to foreign companies and foreign beneficial owners....