Universal Health Services, Inc. v. United States ex rel. Escobar

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Universal Health Services, Inc. v. United States ex rel. Escobar
Seal of the United States Supreme Court.svg
Argued April 19, 2016
Decided June 16, 2016
Full case nameUniversal Health Services, Inc., Petitioner v. United States and Massachusetts, ex rel. Julio Escobar and Carmen Correa
Docket nos. 15–7
Citations579 U.S. ___ ( more )
136 S. Ct. 1989; 195 L. Ed. 2d 348
Opinion announcement Opinion announcement
Holding
"The implied false certification theory can be a basis for [False Claims Act] liability when a defendant submitting a claim makes specific representations about the goods or services provided, but fails to disclose noncompliance with material statutory, regulatory, or contractual requirements that make those representations misleading with respect to those goods or services."
Court membership
Chief Justice
John Roberts
Associate Justices
Anthony Kennedy  · Clarence Thomas
Ruth Bader Ginsburg  · Stephen Breyer
Samuel Alito  · Sonia Sotomayor
Elena Kagan
Case opinions
MajorityThomas, joined by unanimous
Laws applied
False Claims Act

Universal Health Services, Inc. v. United States ex rel. Escobar, 579 U.S. ___ (2016), was a United States Supreme Court case in which the Court held that "the implied false certification theory can be a basis for False Claims Act liability when a defendant submitting a claim makes specific representations about the goods or services provided, but fails to disclose noncompliance with material statutory, regulatory, or contractual requirements that make those representations misleading with respect to those goods or services." [1] [2]

Supreme Court of the United States Highest court in the United States

The Supreme Court of the United States is the highest court in the federal judiciary of the United States. Established pursuant to Article III of the U.S. Constitution in 1789, it has original jurisdiction over a narrow range of cases, including suits between two or more states and those involving ambassadors. It also has ultimate appellate jurisdiction over all federal court and state court cases that involve a point of federal constitutional or statutory law. The Court has the power of judicial review, the ability to invalidate a statute for violating a provision of the Constitution or an executive act for being unlawful. However, it may act only within the context of a case in an area of law over which it has jurisdiction. The court may decide cases having political overtones, but it has ruled that it does not have power to decide nonjusticiable political questions. Each year it agrees to hear about one hundred to one hundred fifty of the more than seven thousand cases that it is asked to review.

The False Claims Act, also called the "Lincoln Law" is an American federal law that imposes liability on persons and companies who defraud governmental programs. It is the federal Government's primary litigation tool in combating fraud against the Government. The law includes a qui tam provision that allows people who are not affiliated with the government, called "relators" under the law, to file actions on behalf of the government. Persons filing under the Act stand to receive a portion of any recovered damages. As of 2012, over 70 percent of all federal Government FCA actions were initiated by whistleblowers. Claims under the law have typically involved health care, military, or other government spending programs, and dominate the list of largest pharmaceutical settlements. The government recovered $38.9 billion under the False Claims Act between 1987 and 2013 and of this amount, $27.2 billion or 70% was from qui tam cases brought by relators.

Contents

Opinion of the Court

Associate Justice Clarence Thomas authored a unanimous opinion. [2]

Clarence Thomas Associate Justice of the Supreme Court of the United States

Clarence Thomas is an American judge, lawyer, and government official who currently serves as an Associate Justice of the Supreme Court of the United States. He is currently the most senior associate justice on the Court following the retirement of Anthony Kennedy. Thomas succeeded Thurgood Marshall and is the second African American to serve on the Court. Among the current members of the Court he is the longest-serving justice, with a tenure of 10,022 days as of April 1, 2019.

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Kellogg Brown & Root Services, Inc. v. United States ex rel. Carter, 575 U.S. ___ (2015), was a United States Supreme Court involving KBR and a former KRB contractor, Benjamin Carter. In a unanimous opinion written by Associate Justice Samuel Alito, the Court held that Wartime Suspension of Limitations Act only applies to criminal offenses. The Court also held that qui tam lawsuits filed under the False Claims Act are no longer considered "pending" after they have been dismissed.

References

  1. ↑ SCOTUSblog coverage
  2. 1 2 Universal Health Services, Inc. v. United States ex rel. Escobar, No. 15–7, 579 U.S. ____ (2016).
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