United States First Circuit

In a qui tam action under the False Claims Act (FCA), claiming that defendants knowingly caused their insureds to file baseless applications for Social Security Disability Insurance (SSDI), thereby burdening the Social Security Administration with the time and expense required to deny such claims, district court's judgment is affirmed in part, vacated in part and remanded where: 1) because the statement at issue is capable of influencing the agency's decision to consider and ultimately pay the claim, it is thus material under the FCA; 2) it was not unreasonable for the jury to conclude that defendant at least had "reckless disregard" for the falsity of the claimants' statements that they were "unable to work" within the meaning of the Social Security Act; but 3) the district court abused its discretion in excluding certain evidence that is highly relevant to one of the elements necessary to prove defendant's liability.

Appellate Information

• Decided 07/29/2010
• Published 07/29/2010

Judges

• STAHL

Court

• United States First Circuit

Counsel

• For Appellant:
  
• William J. Kayatta, Jr., Colette G. Matzzie