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Keywords

defendantliabilityappealpleasummary judgmentcommon lawadmissibility

appealplea

Related Cases

United States ex rel. Doe v. Heart Solution, PC, 923 F.3d 308

Facts

Nita K. Patel and her husband, Kirtish N. Patel, were convicted of defrauding Medicare through two schemes involving false diagnostic reports and unsupervised neurological testing. The United States then filed a civil action against Ms. Patel, her healthcare company Heart Solution P.C., Mr. Patel, and his company Biosound Medical Services. The government sought to hold the defendants liable for violating the False Claims Act and for common law claims, relying on the Patels' prior convictions.

Nita K. Patel and her husband, Kirtish N. Patel, were convicted of defrauding Medicare in a prior criminal proceeding.

Issue

The main legal issues included whether individual employees without ownership interests can be liable under the False Claims Act, the admissibility of unsworn statements in summary judgment, and the application of collateral estoppel regarding the defendants' liability.

The main legal issues included whether individual employees with no ownership interest in a company that presents a fraudulent claim can be liable under the FCA.

Rule

The court ruled that individual employees can be liable under the False Claims Act regardless of ownership interest, unsworn statements not made under penalty of perjury cannot be considered in summary judgment, and collateral estoppel applies only if the party had a full and fair opportunity to litigate the issue in the prior case.

The court ruled that individual employees with no ownership interest in a company can be liable under the FCA.

Analysis

The court found that Ms. Patel's admissions during her plea colloquy established her liability under the False Claims Act, as she acknowledged making false representations to Medicare. The court also determined that the unsworn statement from Mr. Patel could not create a genuine issue of material fact for summary judgment. Furthermore, the court concluded that Heart Solution was not collaterally estopped from contesting liability since it was not a party in the criminal case.

The court found that Ms. Patel's admissions during her plea colloquy established all elements of the FCA claims and that the unsworn statement from Mr. Patel could not create a genuine issue of material fact.

Conclusion

The Court of Appeals affirmed the District Court's judgment regarding Ms. Patel's liability under the False Claims Act and common law fraud but reversed the findings related to Heart Solution and the remaining common law claims against Ms. Patel, remanding for further proceedings.

The Court of Appeals affirmed the judgment of the District Court in part and vacated in part and remanded for further proceedings consistent with this opinion.

Who won?

The United States prevailed in the case, as the court upheld the summary judgment on the False Claims Act and common law fraud claims against Ms. Patel.

The United States prevailed in the District Court and only Ms. Patel and Heart Solution appealed.

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