Duke University $112.5M FCA settlement (March 2019) — largest university FCA payment

In March 2019, Duke University paid $112.5 million in a False Claims Act settlement related to grant applications and progress reports submitted to the National Institutes of Health and the Environmental Protection Agency, involving falsified data attributed to lab analyst Erin Potts-Kant (S-0065). It was the largest False Claims Act payment by a university.

The case priced scientific fraud rather than architectural data unavailability. The FCA mechanism applied because the certifications attached to the grant submissions were knowingly false, satisfying the Act's "knowing or reckless disregard" standard.

The case is critical evidence for C-0025 / M-0003 Term D. It establishes:

1. The settlement range for institutional misconduct under FCA at university scale ($112.5M is the upper anchor).
2. The doctrinal applicability of FCA implied-certification theory to research grant outputs.
3. The political viability of bringing such a case at scale — Duke is among the most prestigious U.S. research universities.

Architectural extension: the doctrinal theory could reach institutions that certify compliance they cannot independently verify, even without intentional fraud. No such case has been brought as of 2026, but the precedent stack would land on adjacent fact patterns at this magnitude if the architectural extension were brought.