False Statement Liability Involving Federal Grantees Curtailed Again
Client Alert | 1 min read | 10.01.04
Musing that, if 18 U.S.C. 1001 were interpreted to prohibit any false statements to any private entity whose funds in part originated with the federal government, a person who lied about his address to get a local library card could be a federal felon, a divided 11th Circuit panel in U.S. v. Blankenship (Aug. 26, 2004) overturned the criminal convictions of the principal of a Disadvantaged Business Enterprise (DBE) under 18 U.S.C. 1001 because the sham contracts are false certified payroll records that were used to obtain payment under a federally-funded state highway project were not statements made to federal agencies. The Eleventh Circuit's analysis, together with the D.C. Circuit's civil False Claims Act decision in U.S. ex rel. Totten v. Bombardier Corp. (see C&M Bullet Point, Sept. 16) represents a significant cutback of federal authority to sanction contractors doing business with federal grantees.
Insights
Client Alert | 4 min read | 04.08.26
Cosmetics Under the Microscope: FDA’s Expanding Regulatory Reach Under MoCRA
The Modernization of Cosmetics Regulation Act of 2022 (MoCRA) marked the most significant expansion of FDA’s authority over cosmetics in 80 years — and the agency is putting that authority to work. From the launch of a new adverse event reporting tool to forthcoming rules on fragrance allergens and good manufacturing practices (GMP), FDA is reshaping the regulatory landscape for manufacturers, packers, and distributors of cosmetic and personal care products.
Client Alert | 11 min read | 04.08.26
Client Alert | 3 min read | 04.07.26
Answering the Top Seven Questions About Pending Section 301 Deadlines
