United States of America ex rel. Jack Palmer, Jr v. Tata Consulting Services, Ltd Defendant—
The Fifth Circuit affirmed the dismissal of a qui tam action under the False Claims Act, holding that an employer has no established duty to pay higher visa fees for visa types it never applied for. The court further ruled that failing to withhold taxes on underpaid wages does not constitute a reverse false claim because the obligation to transmit money to the Treasury arises only after wages are actually paid.