The Atlanta Gleaner.

Legal News

Edited By George Washington

(Testing in progress)

George Washington Statue at Federal Hall

Clarissa Zafirovv.Florida Medical Associates, LLC, et al

CourtUnited States Court of Appeals for the Eleventh Circuit
Docket No.24-13581
DecidedSeptember 1, 2026
JudgesBranch and Luck, Circuit Judges; Moreno, District Judge
Tags
False Claims ActQui TamAppointments ClauseArticle IIConstitutional Law
Case Summary

Clarissa Zafirov, a physician, brought a False Claims Act qui tam suit alleging that health-care companies submitted false diagnosis codes to Medicare. The district court dismissed the case, reasoning that a relator exercises federal authority and therefore must be appointed under the Constitution’s Appointments Clause. The Eleventh Circuit held that qui tam relators do not occupy a continuing office established by law and are not federal officers subject to that Clause. It vacated the dismissal and remanded for the district court to consider the defendants’ separate Take Care and Vesting Clause challenges.

Opinion

Loading published copy…

The Far Side