Is There a Constitutional Limit to Excessive Fines in False Claims Act Cases? Eleventh Circuit Says a Million Dollar Fine for a Few Hundred Dollars in False Claims Is OK
This case Yates v. Pinellas Hematology & Oncology, P.A. is notable for two reasons: First, the Eleventh Circuit recognized that the Eighth Amendment’s prohibition on “excessive fines” applies to False Claims Act cases even where the government declined to intervene. Second, the Court decided that even where the total amount of the false claims was $755.54, fines and penalties of $1,177,000 were not unconstitutionally excessive. In other words, while the prohibition may apply to cases where the government did not intervene, the Court’s ruling also makes clear that “excessiveness” under the Eighth Amendment is not determined by the ratio of the financial loss to the financial penalty.
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