Eleventh Circuit Upholds Constitutionality of False Claims Act's Qui Tam Provision

The U.S. Court of Appeals for the Eleventh Circuit upheld the constitutionality of the False Claims Act's qui tam provision, reversing a lower court's decision. The ruling, in United States ex rel. Zafirov v. Florida Medical Associates, LLC, states that private individuals (relators) bringing fraud claims on behalf of the federal government are not 'officers of the United States' subject to the Appointments Clause. This decision maintains appellate consensus on the issue, though further litigation, potentially to the Supreme Court, is anticipated.