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 | 01.14.26
PFAS Reporting Gets Real in 2026
State regulation of PFAS-containing products will ramp up significantly in 2026. Most notably, companies will have to comply with Minnesota’s sweeping new product-reporting requirements. As we explain below, Minnesota’s requirements cast a wide net, capturing companies that may not sell products directly into the state. This and other features of the state’s reporting program are likely to present significant compliance challenges for a wide range of businesses.
Client Alert | 3 min read | 01.13.26
Client Alert | 7 min read | 01.13.26
Client Alert | 4 min read | 01.13.26
