Davis-Bacon Violation Leads to FCA Liability
Client Alert | 1 min read | 10.16.12
On October 1, the Sixth Circuit in United States ex rel. Wall v. Circle C Constr., LLC, affirmed a decision imposing FCA liability when a prime had submitted inaccurate or false payroll certifications that did not properly describe work done by its subcontractors and that also contained hourly wages for subcontractor employees that did not meet federal guidelines for prevailing wages under the Davis-Bacon Act. This opinion serves as an important reminder to primes and subcontractors that failure to comply with minimum wage rate requirements may have significant adverse consequences and also suggests that companies that learn of such violations must carefully consider whether mandatory disclosure pursuant to FAR Subpart 9.4 or 52.203-13 is required.
Contacts
Insights
Client Alert | 6 min read | 07.17.25
On 11 July 2025, the European Commission published the final version of its Code of Practice for General-Purpose Artificial Intelligence (GPAI). This Code is meant to serve as a tool for GPAI model providers, helping them to comply with the transparency, copyright and security provisions governing general-purpose AI models as set out in the AI Act (arts. 53 and 55), which will become applicable on 2 August 2025. Adherence to the Code is on a voluntary basis.
Client Alert | 3 min read | 07.17.25
(Not the Funniest) Weekend Update: Recap of Recent Developments in the EU-US Tariff Dispute
Client Alert | 5 min read | 07.16.25
Client Alert | 8 min read | 07.16.25
