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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.

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Client Alert | 10 min read | 07.03.25

Focus on Transnational Cartels Continues: FinCEN Targets Three Mexican Financial Institutions with Special Measures, Restricting Their Access to U.S. Financial System

The Orders represent FinCEN’s first actions using new special measures authority under the Fentanyl Sanctions Act and FEND Off Fentanyl Act of 2024 (codified at 21 U.S.C. § 2313a) (the “Fentanyl Act”) and continue the Trump Administration’s broader efforts against transnational cartels and narcotics trafficking....