Closing the Chapter on Generalized False Claims

After eight years of bitterly fought litigation, Carlton Fields assisted hospice provider Chapters Health System Inc. to defeat a $320 million whistleblower suit. The firm's White Collar Crime and Governmental Investigations Group helped our client to continue providing compassionate care for patients who need it the most.

Nancy Chase, a former social worker with Chapters subsidiary LifePath Hospice, alleged substantive violations of the federal and Florida False Claims Acts in a sealed complaint filed in 2010. Six years later, after five iterations of the complaint, the federal district court dismissed Chase's fourth amended complaint with prejudice. The court agreed with Chapters that Chase lacked firsthand knowledge of Chapters' billing practices, finding her allegations of fraud lacked the requisite specificity despite all her previous amendments and the more than 170 allegations in her 41-page complaint.

On appeal, the Eleventh Circuit's three-judge panel unanimously affirmed the district court's ruling. "Although Ms. Chase details a scheme, her complaint does not include specific examples of the conduct she describes or allege the submission of any specific fraudulent claim," the appeals court wrote. "Neither does she allege the basis of her knowledge of the defendants' fraudulent billing practices - a process she was far removed from as a social worker."

Chase appealed her case to the U.S. Supreme Court and attempted to manufacture a circuit split where none existed. The Supreme Court agreed and denied Chase's petition for certiorari.

For Chapters, the win at all three levels of review provides long-awaited comfort and closure - services the hospice provider is known for providing to others - and allows it to continue to focus on doing what it does best: providing compassionate care for patients who need it the most.

©2026 Carlton Fields, P.A. Carlton Fields practices law in California through Carlton Fields, LLP. Carlton Fields publications should not be construed as legal advice on any specific facts or circumstances. The contents are intended for general information and educational purposes only, and should not be relied on as if it were advice about a particular fact situation. The distribution of this publication is not intended to create, and receipt of it does not constitute, an attorney-client relationship with Carlton Fields. This publication may not be quoted or referred to in any other publication or proceeding without the prior written consent of the firm, to be given or withheld at our discretion. To request reprint permission for any of our publications, please use our Contact Us form via the link below. The views set forth herein are the personal views of the author and do not necessarily reflect those of the firm. This site may contain hypertext links to information created and maintained by other entities. Carlton Fields does not control or guarantee the accuracy or completeness of this outside information, nor is the inclusion of a link to be intended as an endorsement of those outside sites.