The Penalty is Fine: Eleventh Circuit Holds Eighth Amendment’s Excessive Fines Clause Applies, But Isn’t Violated, in Non-Intervened FCA Case
To close out 2021, the Eleventh Circuit handed down a lengthy decision on an interesting matter of first impression in the federal courts of appeals—whether, and how, the Eighth Amendment’s Excessive Fines Clause applies to non-intervened FCA cases. While the Eleventh Circuit easily held in Yates v. Pinellas Hematology & Oncology, P.A. that the Excessive Fines Clause applies in such cases, it determined that because the district court assessed a fine within the FCA’s statutorily-prescribed range, Pinellas’ nearly $1.2 million penalty for damages of less than $800 did not violate the Eighth Amendment. Notably, the holding inspired all three judges on the panel to join separate opinions regarding the appropriate level of deference that judges should give to the FCA’s statutory-minimum schema.
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