• University of Michigan, B.A.
  • University of Michigan Law School, J.D.


  • District of Columbia
  • Michigan
  • U.S. Court of Federal Claims
  • U.S. District Court, District of Columbia
  • U.S. Court of Appeals, D.C. Circuit

Charlotte Gillingham


Charlotte Gillingham is a litigation attorney with the Government Contracts Group in the firm’s Washington, D.C. office. She represents government contractors and health care clients in a broad range of trial and litigation matters. Her recent work includes litigating federal and state civil false claims qui tam actions, bid protests, investigations, and compliance counseling. Charlotte is committed to her pro bono work in educational equity, trafficking and asylum, and child custody cases.

Prior to joining Crowell & Moring in 2003, Charlotte served as a law clerk for the Honorable Jeffrey L. Amestoy, Chief Justice of the Vermont Supreme Court.


Admitted to practice: District of Columbia, Michigan, U.S. Court of Federal Claims, U.S. District Court for the District of Columbia, U.S. Court of Appeals for the D.C. Circuit

Professional Activities and Memberships

  • District of Columbia Bar
  • American Bar Association
  • State Bar of Michigan

Representative Matters

  • Served as appellate counsel before the U.S. Court of Appeals for the D.C. Circuit and as trial counsel during a three-week jury trial in a civil False Claims Act (FCA) qui tam action. The case involved allegations of fraud related to submissions to the Export-Import Bank of the U.S., which financed loans issued to several Nigerian states for their purchase of pumping and irrigation equipment from MWI in the early 1990s. The government intervened in the matter and claimed trebled damages in excess of $222 million. After the jury trial, the government dismissed its common law claims with prejudice and the court entered a final judgment of $0 in damages on the government’s FCA claims. The government appealed the damages judgment and MWI cross-appealed on liability. On appeal, the D.C. Circuit overturned the jury verdict, finding that MWI was not liable because it had reasonably interpreted an ambiguous regulation. The U.S. Supreme Court also denied the relator’s petition for writ of certiorari. United States ex rel. Purcell v MWI Corp., 807 F.3d 281 (D.C. Cir. 2015), reh’g en banc denied, cert denied, 137 S. Ct. 625 (2017).
  • Litigated on behalf of a major insurance company in connection with False Claims Act/qui tam action alleging fraud related to grant funding for a renewable energy project under the American Recovery and Reinvestment Act of 2009. Relator’s claims were dismissed with prejudice after motions practice. Obtained dismissal of appeal to D.C. Circuit as well. See United States ex rel. Prescott Lovern v. Deutsche Bank Trust Co. Americas, et al., No. 14-7186 (D.C. Cir.) (Per Curiam opinion, May 6, 2015).
  • Litigated and investigated parallel criminal and civil proceedings involving alleged violations of 18 U.S.C. § 207 (conflicts of interest), 18 U.S.C. § 287 (criminal False Claims Act), 41 U.S.C. § 423 (Procurement Integrity Act), and the civil False Claims Act. The civil FCA litigation involved allegations of improper bid pricing in connection with nearly 30 different contracts with eight separate federal agencies. Government intervened only as to claims related to three contracts with two federal agencies. Criminal allegations resolved through non-prosecution agreement. Civil False Claims Act allegations resolved just prior to filing of motions to dismiss for small fraction of alleged single damages. Previously imposed suspension was lifted. (D.D.C. 2013).
  • Defended global pharmaceutical company in False Claims Act/qui tam action alleging pharmaceutical price reporting fraud in violation of the False Claims. The government did not intervene. Case successfully resolved through settlement following protracted litigation and dismissed with prejudice.
  • Successfully represented major telecommunications company in a D.C. FCA case alleging failure to remit amounts associated with unused calling card minutes under the District of Columbia unclaimed property law. In a case of first impression, the District of Columbia Court of Appeals determined that the False Claims Act allegations were barred under the public disclosure doctrine. (D.C. Court of Appeals, January 2011).
  • Bid Protests. Successfully persuaded the U.S. Court of Federal Claims to enter a Temporary Restraining Order against an award to one the largest security contracts in Iraq. One week later, the U.S. Army agreed that our protest was meritorious and voluntarily took corrective action to remedy the procurement irregularities.
  • Truth in Negotiations Act (TINA). Successfully defended Department of Defense contractor on appeal of the largest defective pricing claim litigated under the Truth in Negotiations Act (TINA) (Fed. Cir. 2006). Work as part of appellate team resulted in precedential rulings on contract pricing, reliance, and causation for government claims involving defective pricing under TINA.

Additional Investigations, Counseling, and Claims Work

  • Successfully handled large fraud investigations for Medicare contractors, resulting in non-intervention decisions by the Department of Justice in qui tam FCA suits.
  • Advised on compliance infrastructure, including reporting lines and best practices protocol.
  • Wrote company practices and procedures for conducting internal investigations, responding to hotline calls, and preparing mandatory disclosures to the government.
  • Represented health care companies in various aspects of health care contracting, including claims, compliance, corporate governance issues, and internal investigations.

Speeches & Presentations

  • "The False Claims Act: Legal Developments and Enforcement Trends: A Look Back, a Look Ahead," Crowell & Moring Webinar (December 6, 2018). Presenters: William S.W. Chang, Brian Tully McLaughlin, Charlotte Gillingham, and Sarah Hill.
  • "Government Contracting 'Triple Play:' Essential Strategies for Winning, Keeping, and Expanding Business," San Diego, CA (June 2008). Presenter: Charlotte Gillingham.
  • “Voluntary Disclosures,” Crowell & Moring’s 2006 Ounce of Prevention Seminar (WOOPS) (April 2006). Co-Presenters: Charlotte Gillingham and Kent Morrison

Client Alerts & Newsletters

Press Coverage

Firm News & Announcements

February 22, 2019 Law360 Names Crowell & Moring's Government Contracts Group a "Practice Group of the Year" for the Ninth Consecutive Year
January 9, 2015 Crowell & Moring's Government Contracts Group Named to Law360's "Practice Groups of the Year" for Fifth Consecutive Year
January 2, 2015 Crowell & Moring Elects Six New Partners and Promotes Eight Associates to Counsel
December 4, 2006 Crowell & Moring Files Supreme Court Amicus Brief For Seven U.S. Senators in Critical School Desegregation Cases Argued Today