False Claims Act's "Rigorous" Materiality Standard Enforced By Second Circuit

The Situation: A decision by the U.S. Court of Appeals for the Second Circuit reinforces the growing body of case law regarding the strict materiality requirements of the False Claims Act.

The Result: Coyne v. Amgen is evidence of the impact the Supreme Court's decision in Universal Health Services, Inc. v. Escobar has had on the FCA's materiality standards.

Looking Ahead: Applying Escobar's "rigorous" standard on a motion to dismiss, Coyne shows that materiality must be alleged with some detail in FCA cases.

The U.S. Court of Appeals for the Second Circuit, in a recent decision in Coyne v. Amgen, Inc., 17-1522-cv, added to the growing body of case law enforcing the False Claims Act's ("FCA") materiality requirement strictly after the Supreme Court's landmark decision in Universal Health Services, Inc. v. Escobar, 136 S. Ct. 1989 (2016). Reviewing the district court's grant of a motion to dismiss under the FCA's public disclosure bar, the Second Circuit