On January 11, 2018, the U.S. District Court for the Middle District of Florida (Merryday, C.J.) issued a blistering opinion vacating a $350 million judgment in a False Claims Act (FCA) case and granting the defendants’ motion for judgment as a matter of law. See United States ex rel. Ruckh v. Salus Rehab., LLC, et al., Case No. 8:11-cv-1303-T-23TBM, 2018 WL 375720 (M.D. Fl. Jan. 11, 2018). The decision is reminiscent of another recent FCA decision, which we reported on here, in which the Fifth Circuit overturned a $650 million judgment following trial and in which – as in Ruckh – the FCA’s “materiality” element prominently influenced the outcome of the case.
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Home Perspectives Court Overturns $350 Million Judgment in FCA Case: Materiality, Scienter, and Causation Standards Preclude Liability by “Zaps, Traps, and Zingers”
A Florida federal court issued a blistering opinion vacating a $350 million judgment in a False Claims Act (FCA) case, and granting the defendants’ motion for judgment as a matter of law. In doing so, the court joined a growing number of cases, that have dismissed claims and granted judgment for defendants, by applying the Supreme Court’s “rigorous and demanding” analysis of materiality and scienter. Significantly, however, this decision also includes a holding that may help parties defending claims that corporate pressure “caused” numerous persons/entities to submit false claims to the government.
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