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Anti-Kickback Statute Violations

The U.S. District Court for the Northern District of Illinois Holds that “But-For” Causation Is Required to Establish FCA/AKS Liability

[06/20/25]

Posted on June 20, 2025 in False Claims Act Defense, Litigation Analysis

Published by: Hall Render

In U.S. ex rel. Wilkerson v. Allergan, the U.S. District Court for the Northern District of Illinois (the “Court”) recently ruled that “but-for” causation is required for liability under the False Claims Act (“FCA”) resulting from alleged Anti-Kickback Statute (“AKS”) violations. This opinion aligns with the First, Sixth and Eighth Circuits, which deviated from the... READ MORE

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