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Will courts clarify the implied false certification theory? Ninth Circuit holds that the Supreme Court established a mandatory test, but the issue remains unsettled

Published Sep 7, 2018Updated Jun 20, 2025

The Congressional Research Service is a nonpartisan policy and legal analysis arm of the Library of Congress. CRS reports are written for members of Congress and their staff, not the public — but they’re made available openly through Congress.gov.

Will courts clarify the implied false certification theory? Ninth Circuit holds that the S… — Informed