Fourth Circuit Draws a Hard Line for FCA Relators: “The Complaint Must Identify the Fire”

Husch Blackwell – On June 4, 2026, The United States Court of Appeals for the Fourth Circuit issued a decision affirming the dismissal of a False Claims Act (FCA) suit for failure to meet Rule 9(b)’s pleading requirements—i.e., failing to state with “particularity the circumstances constituting fraud or mistake.” The decision marks an important victory for FCA defendants faced with vague or imprecise allegations of wrongdoing.