FOIA Release Is FCA 'Public Disclosure'
Client Alert | less than 1 min read | 11.30.09
In U.S. ex rel. Ondis v. City of Woonsocket (1st Cir. Nov.18, 2009), the First Circuit concluded that, under the False Claims Act's public disclosure bar, courts lack subject-matter jurisdiction over qui tam actions when the relator's allegations are based upon information released through Freedom of Information Act requests, finding that FOIA releases of "substantially similar" information which include the essential elements of the alleged fraud qualify as public disclosures. The court noted that it was joining the majority view, adopted by every circuit to consider the issue except the Fourth, taking into account the recent shift by the Seventh Circuit to the majority.
Insights
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Executive Order Creates Women’s Health Task Force, Rescinds Prior Initiatives
On October 19, 2026, President Trump signed an executive order (EO) titled “Advancing Women’s Health to Improve Outcomes in All Phases of Life,” establishing new federal infrastructure dedicated to improving women’s health research, clinical translation, and coordinated policy leadership. The EO creates a White House Women’s Health Task Force and directs the U.S. Department of Health and Human Services (HHS) to establish a new Women’s Health Division within the National Institutes of Health (NIH).
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Africa, MENA, and the Arbitration Act 2025: LCIA’s Latest Report
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CMS Proposal Would Require Extensive Provider Directory Changes in MA
