By Douglas Baruch, John Boese and Jennifer Wollenberg (January 29, 2019, 5:25 PM EST) -- The U.S. Supreme Court's recent interest in civil False Claims Act cases, particularly those involving qui tam relators, is reflected in the court's nine decisions in qui tam cases in the last 13 years. In nearly all of those decisions, the court delineated important limits on relator theories and claims. The most recent example is the court's decision in Universal Health Services v. United States ex rel. Escobar,[1] which validated the implied false certification theory's application to FCA cases, but limited the scope of that theory by mandating that its "demanding" materiality and scienter requirements be rigorously enforced....