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Eighth Circuit Applies Escobar's Materiality Standard

Client Alert | 1 min read | 10.24.16

In U.S. ex rel. Miller v. Weston Educ. Inc. (Oct. 19, 2016), the Eighth Circuit became the first appellate court to apply the materiality standard recently articulated by the Supreme Court in Escobar (discussion of Escobar available here), holding that defendant’s promise to keep accurate grade and attendance records was material in inducing the government to enter into an agreement under the Higher Education Act. The court rejected defendant’s argument that no individual false record caused payment by the government, reasoning instead that the false promise to keep accurate records was material based on the express regulatory conditions of participation, their reasonable importance to payment, and evidence that the government had terminated other institutions that falsified similar records.

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Client Alert | 4 min read | 04.15.26

In Massachusetts, Section 230 Does Not Immunize Meta From Claims That Instagram’s Design Features Injure Children

Meta continues to face lawsuits around the country alleging that its platforms are designed to induce compulsive use by children. In March 2026, a California jury delivered a landmark verdict that Meta and YouTube were liable for allegedly addictive platform features that resulted in a child’s mental health distress.  ...