Compiled from Westlaw WestClip FCA alerts covering April 1 – June 30, 2026.
This document covers the second quarter of 2026 (April 1 – June 30, 2026), continuing the quarterly False Claims Act case summaries. Cases are categorized by statutory provision, with Westlaw citations, courts, and decision dates after each case name.
Coverage focuses on decisions that bear on an FCA legal question—liability elements, qui tam procedure, relator awards and fees, the public-disclosure bar, and retaliation. Purely ancillary rulings in FCA cases (routine discovery, sealing, and similar) are omitted.
2026Q2 (April 1 – June 30, 2026)
31 U.S.C. § 3729(a)(1)(A) and (B) — Liability for False Claims and Statements
United States ex rel. Lynn v. City of Detroit 2026 WL 973955 (U.S.C.A, Sixth Circuit, April 10, 2026) — Affirmed dismissal of a qui tam alleging the City falsely certified compliance in its annual federal-grant Certification, where the complaint failed to plausibly allege a knowingly false presentment or statement under § 3729(a)(1)(A)-(B).
United States ex rel. Bauer v. Republic Services of Montana (Allied Waste) 2026 WL 1283968 (U.S.D.C., D. Montana, May 11, 2026) — Granted a Rule 12(b)(6) dismissal of a qui tam alleging a waste-services contractor misrepresented the products and services it billed to the federal and state governments, ending the case.
United States ex rel. Kuriyan v. Molina Healthcare of New Mexico, Inc. 2026 WL 1470124 (U.S.D.C., D. New Mexico, May 26, 2026) — Addressed the relator’s post-judgment motion to alter or amend the judgment dismissing his federal and state FCA claims against Medicaid managed-care organizations, weighing whether intervening state-law developments warranted relief from the prior dismissal.
United States ex rel. Solano v. Barton Associates, Inc. 2026 WL 1493019 (U.S.C.A, First Circuit, May 28, 2026) — Affirmed dismissal of a qui tam against a medical-staffing agency for failure to plead the alleged scheme to induce false Medicare claims with Rule 9(b) particularity.
United States ex rel. Relator LLC v. McGlauflin (DNT Construction) 2026 WL 1508877 (U.S.D.C., W.D. Texas, May 29, 2026) — Magistrate judge recommended DENYING the defendants’ motion to dismiss a Paycheck Protection Program (PPP) loan-fraud qui tam, finding the relator adequately pleaded the alleged false certifications.
United States ex rel. Kyer v. Thomas Health System, Inc. 2026 WL 1595887 (U.S.C.A, Fourth Circuit, June 4, 2026) — Affirmed dismissal of a multi-defendant hospital qui tam premised on Stark Law/Anti-Kickback-tainted physician-compensation (wRVU) arrangements, for failure to adequately plead the FCA elements across five defendants and three statutes.
United States ex rel. Craig v. Hawthorne Machinery Co. 2026 WL 1653486 (U.S.D.C., S.D. California, June 8, 2026) — Granted the defendants summary judgment against the relator on all claims, entering judgment for the defense.
United States v. Ma (Ma Acupuncture Center, P.C.) 2026 WL 1719074 (U.S.C.A, Fifth Circuit, June 15, 2026) — Affirmed the district court’s enforcement of a settlement the government and an acupuncture provider reached at pre-trial mediation in an FCA suit over inflated Veterans Affairs billings, holding the parties bound their material terms at mediation.
United States v. New Life Center for Change, Inc. (Teen University) 2026 WL 1753972 (U.S.D.C., M.D. Alabama, June 18, 2026) — Entered the parties’ joint consent judgment resolving the government’s FCA claims against a residential group home and its principal.
United States v. Gardner, D.D.S. 2026 WL 1786348 (U.S.D.C., D. New Mexico, June 22, 2026) — In the government’s FCA action against a dentist, resolved a series of motions—denying the defendant’s motions to dismiss for improper/lack of service and under Rule 60(b)(4) and imposing a $4,000 sanction—while addressing the government’s summary-judgment motion.
United States v. Crites 2026 WL 1782154 (U.S.D.C., M.D. Alabama, June 22, 2026) — Denied the pro se defendant’s Rule 59(e)/60(b) motion to set aside a roughly $31 million FCA judgment previously entered on summary judgment.
United States ex rel. Ellis v. CVS Health Corp. 2026 WL 1791002 (U.S.D.C., E.D. Pennsylvania, June 22, 2026) — Granted CVS summary judgment, rejecting a ‘worthless services’ theory premised on temperature-excursion risk to shipped biologic medications where the relator produced no evidence that any drug’s efficacy was actually impaired.
United States ex rel. Cobb v. Charleston County School District 2026 WL 1830950 (U.S.D.C., D. South Carolina, June 25, 2026) — Granted in part and denied in part the district’s motion to dismiss—dismissing the state whistleblower claim, allowing the FCA claim to proceed, and ordering the relator to file a more definite statement of the FCA claim.
United States ex rel. White v. Gainwell Technologies LLC 2026 WL 1864033 (U.S.D.C., D. Massachusetts, June 29, 2026) — Granted dismissal, concluding on fuller briefing that the relators failed to state an FCA claim against a state Medicaid fiscal agent—reversing the court’s earlier view when it had allowed the amendment.
31 U.S.C. § 3730(b) — Actions by Private Persons (Qui Tam)
United States ex rel. Nicholson v. Clarksville Pain Institute, LLC 2026 WL 908546 (U.S.D.C., M.D. Tennessee, April 2, 2026) — Granted the United States leave to amend its complaint-in-intervention in a qui tam alleging pain-clinic billing fraud, after the government partially intervened.
United States ex rel. Duell v. State of Hawaii 2026 WL 915149 (U.S.D.C., D. Hawaii, April 3, 2026) — Ordered a pro se relator to show cause why his ‘qui tam’ complaint should not be dismissed—because a non-attorney cannot prosecute an FCA action on the government’s behalf—and directed the clerk to unseal the complaint.
United States ex rel. Buxbaum v. Legal Aid Society of Rockland County 2026 WL 926728 (U.S.D.C., S.D. New York, April 6, 2026) — Dismissed a pro se plaintiff’s attempt to reframe his suit as an FCA qui tam, for lack of subject-matter jurisdiction.
United States ex rel. Compton v. HCR ManorCare, Inc. 2026 WL 1066520 (U.S.D.C., E.D. Pennsylvania, April 17, 2026) — Granted a defendant’s motion to unseal the docket in a consolidated nursing-home ‘worthless services’ qui tam, subject to the government’s opportunity to seek limited redactions.
United States ex rel. Dow v. HC2, Inc. 2026 WL 1179712 (U.S.D.C., District of Columbia, April 30, 2026) — Dismissed a qui tam for failure to prosecute where the relator—who must be represented by counsel—went nine months without replacement counsel; also ruled in part on unsealing.
United States ex rel. v. Hospice Source, LLC 2026 WL 1189202 (U.S.D.C., E.D. California, April 30, 2026) — Dismissed a qui tam with prejudice as to the relator and without prejudice as to the United States and plaintiff States under Rule 41, consistent with the FCA’s § 3730(b)(1) requirement of court and Attorney General consent.
United States ex rel. Chao v. County of Santa Clara 2026 WL 1395940 (U.S.D.C., N.D. California, May 18, 2026) — Dismissed the pro se plaintiff’s FCA qui tam and FCA retaliation claims without leave to amend.
United States ex rel. Doe v. Trustees of Columbia University 2026 WL 1533795 (U.S.D.C., S.D. New York, May 28, 2026) — On a pro se relator’s in forma pauperis and pseudonym requests in a purported qui tam, granted 60 days to retain counsel, reiterating that a non-attorney cannot pursue an FCA action pro se.
United States ex rel. Scheffler v. Golden Shovel Agency, LLC 2026 WL 1723921 (U.S.D.C., D. Minnesota, June 15, 2026) — Granted in part a motion to dismiss a CARES Act/PPP-funding qui tam but gave the relator leave to file a second amended complaint.
31 U.S.C. § 3730(d) — Award to Qui Tam Plaintiff
United States ex rel. Thrower v. Academy Mortgage Corp. 2026 WL 923856 (U.S.C.A, Ninth Circuit, April 6, 2026) — In companion appeals arising from an FCA relator’s award of attorneys’ fees, costs, and expenses, the court addressed the fee award—including when postjudgment interest begins to accrue on it—affirming the district court (see also 2026 WL 923862).
United States ex rel. Osinek v. Permanente Medical Group, Inc. (Kaiser) 2026 WL 970482 (U.S.D.C., N.D. California, April 10, 2026) — Denied a third party’s motion for a share of the settlement proceeds in the consolidated Kaiser Medicare Advantage risk-adjustment qui tam actions.
United States ex rel. Quesenberry v. Breaks Interstate Park Commission (Rockbridge Regional Library) 2026 WL 1534496 (U.S.D.C., W.D. Virginia, June 1, 2026) — Awarded the relator $3,400 of the $12,600 sought in attorneys’ fees connected to a defendant library’s default.
31 U.S.C. § 3730(e)(4) — The Public Disclosure Bar
United States ex rel. Anderson v. Saint Elizabeth Medical Center, Inc. 2026 WL 1047118 (U.S.C.A, Sixth Circuit, April 17, 2026) — Affirmed judgment on the pleadings for the hospital, holding the relator’s allegations of medically unnecessary procedures and kickbacks were substantially the same as publicly disclosed information and that he was not an original source (also failing Rule 9(b) particularity).
31 U.S.C. § 3730(h) — Relief From Retaliatory Actions
Brandt v. Federal Reserve Bank of San Francisco 2026 WL 1224044 (U.S.D.C., W.D. Washington, May 5, 2026) — Dismissed the plaintiff’s FCA retaliation claim without prejudice and granted leave to amend, while dismissing her related ‘outrage’ tort claim with prejudice.
Evans v. Individual Advocacy Group, Inc. 2026 WL 1250650 (U.S.D.C., District of Columbia, May 7, 2026) — Denied the employer’s motion to dismiss the FCA retaliation claim, allowing the theory that the plaintiff was fired for protected activity to proceed (and denying a related discovery motion as moot).
Deedrich v. Danville Redevelopment & Housing Authority 2026 WL 1398780 (U.S.D.C., W.D. Virginia, May 19, 2026) — Granted the employer summary judgment on the plaintiff’s § 3730(h) constructive-discharge retaliation claim.
Young v. Rector & Visitors of the University of Virginia 2026 WL 1557470 (U.S.D.C., W.D. Virginia, June 2, 2026) — Granted in part motions to dismiss physician-plaintiffs’ claims arising from alleged fraudulent-billing pressure, dismissing their FCA and Virginia FATA claims (and RICO claims) without prejudice.
Akindutire v. Northrop Grumman Systems Corp. 2026 WL 1661915 (U.S.D.C., D. Minnesota, June 9, 2026) — Granted the employer’s motion to compel arbitration of the plaintiff’s claims, including his FCA retaliation claim (Count III).
John Libby is an arbitrator, mediator, and settlement counsel with LibbyADR LLC. This summary is provided for general informational purposes and is not legal advice.