Seventh Circuit: Sheet Metal Workers Internatio v. Horning Investments, LLC


Labor, FCA


Union can bring a False Claims Act action relative to its members work -- primary jurisdiction of the Department of Labor does not displace the claim to the NLRB.

Payroll deductions for an insurance plan for which the worker was not yet eligible did not constitute a violation of the relevant Act.

Reliance on accountants dos not completely dispel mens rea.


Sheet Metal Workers Internatio v.   Horning Investments, LLC