Terra White Fulham

(January 22, 2026) - Michael D. Granston, Terra W. Fulham, Binx Saunders and Nina M. Gayleard of Covington & Burling LLP discuss the U.S. Supreme Court's decision expanding the scope of the wire fraud statute and its potential impact on civil False Claims Act cases. In Kousisis v. United States,1 the Supreme Court unanimously confirmed that liability under the criminal wire fraud statute can extend to misrepresentations even where there is no proof that the victim suffered a net economic loss.

On September 18, 2025, the Department of Justice (“DOJ”) announced a civil False Claims Act (“FCA”) settlement against a New Jersey shipbuilder to resolve allegations that it improperly employed unauthorized aliens to work on Navy ships. The settlement, which exceeded $4 million, is the second this year involving government contractors alleged to have employed unauthorized aliens in violation of FAR 52.222-54, Employment Eligibility Verification.

On July 14, 2025, the U.S. Department of Justice (DoJ) and General Services Administration (GSA) announced a $14.75 million settlement of Civil False Claims Act allegations against IT company Hill ASC Inc. (Hill). This settlement is consistent with the current Administration’s focus on “fraud, waste, and abuse” in government procurement and the recent DoJ FCA initiative focused on cybersecurity fraud.