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Part 2 of 2: U.S. Supreme Court Confirms False Claims Act’s Scienter Standard Accounts for Subjective Intent

On June 1, 2023, the U.S. Supreme Court released a unanimous decision in U.S. ex rel. Schutte v. SuperValu Inc., No. 21-1326; U.S. ex rel. Proctor v. Safeway, Inc., No. 22-111, clarifying the False Claims Act’s scienter...more

First Circuit Overturns Conspiracy Convictions in Varsity Blues College Admissions Case

The First Circuit applied a narrow definition of “bribery” for honest services fraud under 18 U.S.C. § 1346. Payments made to the purportedly harmed party in the alleged bribery scheme—here, the universities—cannot...more

Third Circuit Rejects Use Of “Intended Loss” as Enhancement Under U.S. Sentencing Guidelines

The Third Circuit Court of Appeals ruled yesterday in United States v. Banks1 that under the U.S. Sentencing Guidelines, “loss” means only actual loss and not intended loss. Although the term “loss” is not explicitly...more

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