False Claims Act Year in Review: 2024

In fiscal year 2024, the Department of Justice’s total False Claims Act (FCA) recoveries through settlements and judgments exceeded $2.9 billion. This reflects a 4.5-percent increase from last year’s number and the largest amounts recovered in the last three years.

There were many other significant developments for FCA defendants in 2024. Courts have begun applying the Supreme Court’s 2023 decision in United States ex rel. Polansky v. Executive Health Resources, Inc., 599 U.S. 419 (2023), which established the standards for motions by the government to intervene and seek the dismissal of a qui tam action. The cases have demonstrated that, in the aftermath of Polansky, the government possesses significant discretion to dismiss such lawsuits notwithstanding a relator’s objection to dismissal. Lower courts have also been asked to resolve whether the FCA’s qui tam provisions and large monetary penalties for FCA violations are unconstitutional.

These and other developments, emerging trends, and high-profile FCA cases will be addressed in detail in this 2024 year in review.