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.
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Client Alert | 7 min read | 12.17.25
After hosting a series of workshops and issuing multiple rounds of materials, including enforcement notices, checklists, templates, and other guidance, the California Air Resources Board (CARB) has proposed regulations to implement the Climate Corporate Data Accountability Act (SB 253) and the Climate-Related Financial Risk Act (SB 261) (both as amended by SB 219), which require large U.S.-based businesses operating in California to disclose greenhouse gas (GHG) emissions and climate-related risks. CARB also published a Notice of Public Hearing and an Initial Statement of Reasons along with the proposed regulations. While CARB’s final rules were statutorily required to be promulgated by July 1, 2025, these are still just proposals. CARB’s proposed rules largely track earlier guidance regarding how CARB intends to define compliance obligations, exemptions, and key deadlines, and establish fee programs to fund regulatory operations.
Client Alert | 1 min read | 12.17.25
Client Alert | 2 min read | 12.16.25
Client Alert | 11 min read | 12.15.25
New York LLC Transparency Act: Key Requirements and Deadlines
