D.C. Circuit Creates Split over the Reach of the First-to-File Bar
Client Alert | 1 min read | 04.18.14
In U.S. ex rel. Shea v. Verizon Co., the D.C. Circuit held that (1) two complaints may be "related" even if they involve different agencies or contracts, (2) the bar applies even when the same relator filed the earlier action, and (3) it continues to operate even after the earlier-filed action is resolved. The third holding (which drew a dissent) conflicts with dicta from two other circuits and the Fourth Circuit's 2013 opinion in U.S. ex rel. Carter v. Halliburton Co., petition for cert. filed (discussed here), holding that the first-to-file bar only applies while the earlier action is still pending.
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On 30 December 2025, the Belgian Official Gazette published the Act of 19 December 2025 implementing a strengthened return-to-work policy in case of work incapacity, and the Royal Decree of 17 December 2025 amending the Code of Well-being at Work, commonly referred to as "Reintegration Trajectory 3.0".
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