1. Home
  2. |Insights
  3. |Eighth Circuit Applies Escobar's Materiality Standard

Eighth Circuit Applies Escobar's Materiality Standard

Client Alert | 1 min read | 10.24.16

In U.S. ex rel. Miller v. Weston Educ. Inc. (Oct. 19, 2016), the Eighth Circuit became the first appellate court to apply the materiality standard recently articulated by the Supreme Court in Escobar (discussion of Escobar available here), holding that defendant’s promise to keep accurate grade and attendance records was material in inducing the government to enter into an agreement under the Higher Education Act. The court rejected defendant’s argument that no individual false record caused payment by the government, reasoning instead that the false promise to keep accurate records was material based on the express regulatory conditions of participation, their reasonable importance to payment, and evidence that the government had terminated other institutions that falsified similar records.

Insights

Client Alert | 12 min read | 03.10.26

EU Sustainability Reporting Revamp: Key Updates to the CSRD and the CS3D from the Omnibus I Directive

On 26 February 2026, the EU published Directive (EU) 2026/470 (the Omnibus I Directive). Adopted as part of the European Commission's (Commission) simplification agenda and after a year of debates and negotiations between the Commission, the Council, and the European Parliament, this text effectuates far-reaching changes to both the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CS3D)....