Absent Evidence of False Claims, Complaint About Regulatory Violation Not Protected Conduct Under FCA; United States District Court for the District of Massachusetts No. 14-13155-PBS, Ebonia Elliott-Lewis v. Abbott Laboratories

The district court granted the defendant’s motion for summary judgment on two claims of unlawful retaliation under the FCA, finding that the plaintiff failed to connect violations of internal company policy and certain healthcare regulations to the submission of false claims to the government.