Richard Strassberg William Harrington

Richard Strassberg William Harrington

September 27, 2018 | New York Law Journal

Circuit Rulings on Civil Investigative Demands Show Agency Deference Is Not Unconditional

In their Federal Civil Enforcement column, Richard Strassberg, William Harrington and Lauren Bowman discuss two rulings which demonstrate that a boilerplate CID recitation that it is being issued to investigate potential violations of law, without specific details about the nature of that investigation, may present a basis to challenge the enforcement of that CID.

By Richard Strassberg, William Harrington and Lauren Bowman

9 minute read

June 28, 2018 | New York Law Journal

Two Recent Cases Illustrate Need to Rely on Causal Concepts in FCA Cases

In their Federal Civil Enforcement column, Richard Strassberg, William Harrington and Annie E. Railton write: In 2010, Congress amended the anti-kickback statute (AKS) to confirm that claims “resulting from” illegal kickbacks are false and thus actionable under the federal False Claims Act (FCA).

By Richard Strassberg, William Harrington and Annie E. Railton

1 minute read

September 19, 2014 | New York Law Journal

Dodd-Frank's New Deputies—States

In their Federal Civil Enforcement column, Richard Strassberg, William Harrington and Benjamin P. Saul write: In the wake of the Financial Crisis, the federal government has invigorated its civil fraud enforcement. The DOJ has dominated the headlines in this area with a series of significant lawsuits and resolutions involving mortgage lenders. Yet, behind the headlines, a curious, new category of enforcers is emerging to target violations of federal civil consumer financial protection laws: state agencies and attorneys general.

By Richard Strassberg, William Harrington and Benjamin P. Saul

11 minute read