Supreme Court Hears Argument on Implied Certification Theory
Client Alert | 1 min read | 04.20.16
On April 19, 2016, the Supreme Court heard oral argument in U.S. v. Universal Health Servs., Inc., which concerns (1) whether the implied certification theory of legal falsity under the FCA is ever viable; and (2) if it is, whether a contractor’s reimbursement claim can be legally false under that theory if the contractor fails to comply with a statute, regulation, or contractual provision that is not an explicit condition of payment. In a post on the Whistleblower Watch Blog, C&M attorneys share first impressions from yesterday’s argument and examine the significance of the case for government contractors who could face potential FCA exposure for failure to comply with myriad contract provisions or regulations.
Contacts
Insights
Client Alert | 7 min read | 11.05.26
2026 State Attorney General Elections: What Businesses Should Expect
As of November 4, 2026, the state attorney general elections point to increased enforcement in 2027, particularly in consumer protection, antitrust, AI, health care, and data centers.[1] Businesses should prepare for more investigations under existing laws and proposals for new legislation or rules. Campaign commitments indicate priorities, but their timing and implementation remain uncertain.[2]
Client Alert | 3 min read | 11.04.26
CMS Proposal Would Overhaul Eligibility Rules for ACA Exchanges
Client Alert | 7 min read | 11.04.26
FDA Issues Guidance on Prescription Drug Use-Related Software
Client Alert | 7 min read | 11.02.26
