Davis-Bacon Violation Leads to FCA Liability
Client Alert | less than 1 min read | 10.16.12
On October 1, the Sixth Circuit in United States ex rel. Wall v. Circle C Constr., LLC, affirmed a decision imposing FCA liability when a prime had submitted inaccurate or false payroll certifications that did not properly describe work done by its subcontractors and that also contained hourly wages for subcontractor employees that did not meet federal guidelines for prevailing wages under the Davis-Bacon Act. This opinion serves as an important reminder to primes and subcontractors that failure to comply with minimum wage rate requirements may have significant adverse consequences and also suggests that companies that learn of such violations must carefully consider whether mandatory disclosure pursuant to FAR Subpart 9.4 or 52.203-13 is required.
Contacts
Insights
Client Alert | 4 min read | 04.23.26
Bipartisan Coalition of State AGs Backs Federal PBM Transparency Rule
In mid-April, a bipartisan coalition of 45 State Attorneys General (AG) submitted a formal letter to the U.S. Department of Labor (DOL) expressing their collective support for a proposed rule (Improving Transparency into Pharmacy Benefit Manager Fee Disclosure, or RIN 1210-AB37), which would — if enacted — impose new disclosure obligations on pharmacy benefit managers (PBM) regulated under the Employee Retirement Income Security Act of 1974 (ERISA).
Client Alert | 5 min read | 04.23.26
Client Alert | 3 min read | 04.23.26
Crowell Tracker of Court Rulings on Legal Privilege and Artificial Intelligence Tools
Client Alert | 2 min read | 04.23.26
Two Lawsuits in One: The Growing Risk of Pairing Biometric Tech With Wage-and-Hour Violations
