Reverse False Claim Requires "Established" Obligation to Pay
Client Alert | less than 1 min read | 12.15.16
On December 13, 2016, the Fifth Circuit, reversing the district court, held in U.S. ex rel. Simoneaux v. E.I. DuPont De Nemours & Co that the 2009 amendments to the FCA did not abrogate its prior precedent holding that reverse false claims liability did not extend to potential or contingent obligations to pay unassessed government fines or penalties. Agreeing with both the defendant and, notably, the United States, the court concluded that, while the 2009 amendments clarified that the amount of the obligation need not be “fixed,” the duty to pay had to be “established” before liability could attach.
Insights
Client Alert | 1 min read | 06.02.25
Job Corps Centers: Widespread Contract Terminations due to Agency’s “Pause”
On May 29, 2025, the Department of Labor (DOL) announced that it will begin a “phased pause in operations at contractor-operated Job Corps centers nationwide.” The pause is anticipated to occur within a month—by June 30, 2025. To effectuate this pause, DOL has suspended operations at approximately one hundred contractor-operated Job Corps centers. DOL instructed centers to suspend program activities, transition students home, and implement other transition plans. According to DOL’s Frequently Asked Questions, the Department anticipates that students will transition to “state and local workforce partners” including American Job Centers and the Labor Exchange system in their home state.
Client Alert | 5 min read | 06.02.25
Client Alert | 3 min read | 06.02.25
Client Alert | 5 min read | 05.30.25
