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Seal Violation Does Not Mandate Dismissal, Supreme Court Says

Client Alert | 1 min read | 12.07.16

On December 6, 2016, the Supreme Court in State Farm and Casualty Co. v. U.S. ex rel. Rigsby rejected the argument that a violation of the FCA’s seal requirement — here, disclosure of the allegations of the sealed complaint to the news media by relator’s counsel — mandates dismissal of a relator’s complaint, holding instead that such a determination is better left to the discretion of the district court. The Court reasoned that the FCA is silent as to the remedy for violating the seal provision, whereas it expressly mandates dismissal elsewhere, and that a rule mandating dismissal could harm the government’s interests —which the seal requirement was meant to protect — by depriving the government of assistance from relators on which it relies to prosecute FCA claims.

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Client Alert | 5 min read | 06.05.26

Grants Overhauled: What the Proposed Rewrite of 2 CFR Part 200 Means for Federal Financial Assistance Award Recipients

The Office of Management and Budget issued on May 29, 2026 a Proposed Rule that would significantly revise the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) at 2 C.F.R. Part 200, potentially impacting the full lifecycle of federal grants, cooperative agreements and other forms of financial assistance, from pre-award merit review through post-award administration and termination. These proposed changes are designed to implement the President’s policy priorities, executive actions related to diversity, equity and inclusion (DEI) activities, and Executive Order No. 14332, Improving Oversight of Federal Grantmaking (EO 14332)....