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ASBCA Rejects the Government’s Use of "Prior Material Breach" Affirmative Defense

Client Alert | 1 min read | 09.24.19

In Engility, LLC, ASBCA No. 61281 (August 19, 2019), the ASBCA denied the government’s motion to amend its answer to include the affirmative defense of prior material breach. The matter involved the government’s disallowance of settlement costs paid by Engility following a lawsuit in which Iraqi plaintiffs alleged that Engility’s employees engaged in abuse at Abu Ghraib. Before the government’s motion, the parties had engaged in costly and time consuming discovery after the government argued that under Geren v. Tecom, Inc., 566 F.3d 1037 (Fed. Cir. 2009), Engility had to demonstrate that none of its employees engaged in the alleged abusive conduct, and therefore the Iraqi plaintiffs had very little likelihood of success on the merits. Engility opposed the government’s motion to amend its answer because, among other reasons, the amendment would exponentially expand the scope of already extensive discovery. The ASBCA requested supplemental briefing on the government’s motion, which clarified the government’s position: the affirmative defense of Engility’s alleged prior material breach would be invoked only in the event the Board found that Engility’s settlement costs were allowable and, thus, the government’s disallowance would breach the contract’s Allowable Cost and Payment clause. The government also stated that it did not intend to argue that Engility’s alleged prior material breach was related to the Iraqi plaintiff’s allegations.  In denying the motion, the Board stated that “It is a legal impossibility for the government to raise the affirmative defense of prior material breach as a defense against what the government itself admits is essentially the possibility that its own claim may fail.” 

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Client Alert | 5 min read | 12.12.25

Eleventh Circuit Hears Argument on False Claims Act Qui Tam Constitutionality

On the morning of December 12, 2025, the Eleventh Circuit heard argument in United States ex rel. Zafirov v. Florida Medical Associates, LLC, et al., No. 24-13581 (11th Cir. 2025). This case concerns the constitutionality of the False Claims Act (FCA) qui tam provisions and a groundbreaking September 2024 opinion in which the United States District Court for the Middle District of Florida held that the FCA’s qui tam provisions were unconstitutional under Article II. See United States ex rel. Zafirov v. Fla. Med. Assocs., LLC, 751 F. Supp. 3d 1293 (M.D. Fla. 2024). That decision, penned by District Judge Kathryn Kimball Mizelle, was the first success story for a legal theory that has been gaining steam ever since Justices Thomas, Barrett, and Kavanaugh indicated they would be willing to consider arguments about the constitutionality of the qui tam provisions in U.S. ex rel. Polansky v. Exec. Health Res., 599 U.S. 419 (2023). In her opinion, Judge Mizelle held (1) qui tam relators are officers of the U.S. who must be appointed under the Appointments Clause; and (2) historical practice treating qui tam and similar relators as less than “officers” for constitutional purposes was not enough to save the qui tam provisions from the fundamental Article II infirmity the court identified. That ruling was appealed and, after full briefing, including by the government and a bevy of amici, the litigants stepped up to the plate this morning for oral argument....