UNITED STATES v. MOLINA HEALTHCARE OF ILLINOIS
Nov 21, 2021OUTCOME:
A landmark decision from the 7th Circuit Court of Appeals. In United States ex rel. Prose v. Molina Healthcare of Illinois, 10 F.4th 765 (7th Cir. 2021), the Seventh Circuit revived a qui tam False Cla ... ims Act suit that the district court had dismissed. The majority held the relator adequately pleaded all three FCA theories: factual falsity, fraudulent inducement of the 2016–17 renewals, and implied false certification. It found materiality plausibly alleged largely from the size of the rate-cell differential. It rejected, as premature, Molina's argument that the government's continued payment and renewals despite knowledge showed immateriality. This case matters because it gives relators in the Seventh Circuit a comparatively lenient pleading path.
