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  3. |“It’s Alive!” High Court Recognizes “Frankenstein’s Monster” Theory of FCA Liability

“It’s Alive!” High Court Recognizes “Frankenstein’s Monster” Theory of FCA Liability

Client Alert | 1 min read | 06.24.16

In Universal Health Servs. v. U.S. ex rel. Escobar, the Supreme Court unanimously held that a defendant may be liable under the FCA when, in connection with a claim for payment submitted to the government, the defendant “makes specific representations about the goods or services provided” and fails to disclose noncompliance with material statutory, regulatory, or contractual requirements that makes the representations “misleading half-truths.” In a "Feature Comment" published in The Government Contractor, C&M attorneys analyze the Court’s opinion, the legal and factual context in which it arose, and its likely effect on federal government contractors.

Insights

Client Alert | 2 min read | 02.18.26

DHS Announces Virtual Town Halls on CIRCIA Final Rule

On February 13, 2026, the U.S. Department of Homeland Security (DHS) announced upcoming virtual town hall meetings scheduled for March 2026 regarding the implementation of the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (CIRCIA).  The meetings will allow industry stakeholders to provide input to DHS to refine the “scope and burden” of the forthcoming CIRCIA final rule....