A federal district court in the Middle District of Florida entered a precedent-setting order on a pending motion to dismiss in which she concluded that the qui tam provisions of the Federal False Claims Act violate Article Two of the U.S. Constitution.

The case involves a False Claims Act action, where the defendant, Florida Medical Association, moved for a motion to dismiss Clarissa Zafirov's complaint. Zafirov, the plaintiff, is a board-certified family medicine physician, who worked for Florida Medical Associates, one of the named defendants in this case.