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U.S. ex rel. Schwartz v. DRNY: FCA Retaliation Claim Survives

Writer: Joe Whitcomb
Joe Whitcomb
Sep 14, 2025
1 min read

Updated: 3 days ago

Quintin Schwartz alleged that Document Reprocessors of New York violated prevailing-wage requirements on FEMA-funded work and retaliated against him after he raised compliance concerns. The federal district court found the FCA fraud allegations insufficient under the applicable pleading standards and dismissed that portion of the case. It nevertheless concluded that Schwartz plausibly alleged protected conduct, employer knowledge, and retaliatory termination, allowing the FCA retaliation claim to proceed.

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