Summary The U.S. Supreme Court has issued two major decisions on the False Claims Act ("FCA") this month. In United States ex rel. Schutte v. SuperValu, Inc. and United States ex rel. Proctor v. Safeway, Inc., the Court rejected an "objective reasonableness" knowledge standard in cases where the false claim is based on an alleged misrepresentation of compliance with an ambiguous legal requirement, in favor of one based on the defendant's subjective belief about that requirement.