Profit Seeking Is Not Fraudulent
Client Alert | less than 1 min read | 10.12.12
In United States ex rel. Williams v. Renal Care Group, Inc., the Sixth Circuit found the defendants did not knowingly submit false claims to Medicare when they followed industry practices and sought guidance -- both from outside legal counsel and the government -- on how to follow ambiguous federal regulations, even though the contractors sought to maximize government payments. The court dismissed the idea that contractors "ought to be punished solely for seeking to maximize profits" and rejected the government's argument that the companies had "recklessly" misinterpreted the regulations to do so.
Insights
Client Alert | 3 min read | 03.12.26
DOJ Releases First-Ever Department-Wide Corporate Enforcement and Voluntary Self-Disclosure Policy
On March 10, 2026, the Department of Justice released the first-ever Department-wide Corporate Enforcement and Voluntary Self-Disclosure Policy (the “Department-wide CEP” or “Policy”), which applies to all non-antitrust corporate criminal cases across the Department. The new policy has been anticipated since December 2025, when Deputy Attorney General Todd Blanche announced the Department’s plans to release a new, single corporate enforcement policy for all criminal matters. According to the Department, the new policy is designed to “help ensure consistency across the Department” and “transparently describe the Department’s policies and decisionmaking.”
Client Alert | 3 min read | 03.12.26
Client Alert | 2 min read | 03.11.26
