Eighth Circuit Breathes New Life into Rule 9(b)

Adding to the already-muddled case law regarding precisely what must be pleaded with particularity under Rule 9(b), in a 2-1 decision, the Eighth Circuit recently breathed life into the requirement that a relator who does not identify representative false claims must nonetheless at least plead facts that provide "reliable indicia that lead to a strong inference that claims were actually submitted." In United States ex rel.