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DOJ's Procurement Collusion Strike Force Amps Up Its Enforcement Ranks

Client Alert | 1 min read | 11.13.20

Just days after the anniversary of its launch, the Department of Justice’s Procurement Collusion Strike Force has expanded its ranks to include 11 new national partners. The U.S. Air Force Office of Special Investigations and the Department of Homeland Security’s Office of Inspector General, as well as nine additional U.S. Attorneys’ Offices, have joined the government’s effort to combat collusion, fraud, and antitrust crimes in the public procurement process. Assistant Attorney General Makan Delrahim promised “even more success” for the PCSF in the coming year “[b]y growing [its] national footprint, and folding in additional subject-matter experts.” The PCSF currently has more than 360 agent, analyst, and other law enforcement and OIG working members, hailing from 46 unique agencies and offices at the federal, state, and local levels.

This expansion – on top of news that DOJ has appointed Daniel Glad, former assistant chief of the Chicago field office, as the PCSF’s first permanent director – underscores the Antitrust Division’s continued focus on potential antitrust violations involving public procurement and the increased importance of enlisting counsel experienced in both antitrust and government contracts.

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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....