The False Claims Act has for decades been the government’s primary anti-fraud statute. The Department of Justice has used the law to recover more than $70 billion since 1986, largely in cases related to health care and defense contracting. Under the FCA,
To the surprise of few informed observers, Friday’s decision in Axon Enterprise v. Federal Trade Commission confirmed a new avenue for pre-enforcement challenges to the administrative proceedings of federal agencies. Traditionally, when an agency institut
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