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.
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Client Alert | 5 min read | 07.14.25
The European Commission issues competition guidance in the transport sector
On July 9, 2025, the Directorate-General for Competition within the European Commission issued two informal guidance letters, both intended to bring increased clarity on competition law compliance to companies in the transport sector.
Client Alert | 4 min read | 07.11.25
Client Alert | 7 min read | 07.11.25
President Trump’s “One Big Beautiful Bill” Makes Changes to Medicaid
Client Alert | 4 min read | 07.11.25
