The Eleventh Circuit Court of Appeals upheld a $27.5 million judgment against a Georgia doctor and his medical practice for Medicare fraud, affirming one of the largest False Claims Act penalties imposed on an individual healthcare provider.
In *United States v. Charles Adams* (11th Cir. 2026), the appeals court rejected challenges by Dr. Charles C. Adams and his business, Charles C. Adams, M.D., P.C., doing business as Full Circle Medical Center. A jury had found Adams liable for violating the False Claims Act by submitting 4,407 false claims to Medicare.
The case originated in the U.S. District Court for the Northern District of Georgia, which imposed $27,567,729 in damages following the jury verdict. Adams appealed the district court's decision, but the three-judge panel consisting of Circuit Judges Newsom, Grant, and Abudu unanimously affirmed the lower court's ruling after oral argument.
The False Claims Act allows the federal government to recover damages from individuals and entities that submit false or fraudulent claims for government payment. Under the statute, violators can face penalties of up to three times the government's damages plus additional civil penalties for each false claim submitted.
Medicare, the federal insurance program that provides coverage for individuals aged 65 or older and those with end-stage renal disease, operates under strict coverage rules administered by the Centers for Medicare and Medicaid Services. The program only covers items and services that are "reasonable and necessary for the diagnosis or treatment of illness or injury," according to federal law.
The case highlights ongoing federal efforts to combat healthcare fraud, which costs taxpayers billions of dollars annually. Healthcare fraud prosecutions have become increasingly common as the government uses both criminal and civil enforcement tools to recover fraudulent payments and deter future violations.
False Claims Act cases often involve allegations that healthcare providers billed for services not rendered, submitted claims for medically unnecessary procedures, or otherwise misrepresented the nature of services provided to government healthcare programs. The statute includes a whistleblower provision that allows private individuals with knowledge of fraud to file lawsuits on behalf of the government and potentially receive a portion of any recovery.
The Adams case represents a significant enforcement victory for federal prosecutors, who have made healthcare fraud a priority in recent years. The $27.5 million judgment demonstrates the substantial financial consequences providers can face when found liable under the False Claims Act.
For healthcare providers, the decision serves as a reminder of the importance of compliance with Medicare billing requirements and the severe penalties that can result from submitting false claims. The case also illustrates how False Claims Act violations can result in both individual and corporate liability, as both Adams personally and his medical practice were held responsible for the fraudulent billing.
The appeals court's decision to affirm the district court judgment means Adams and his practice remain liable for the full $27.5 million penalty. The ruling is designated "not for publication," meaning it will not serve as binding precedent for future cases, though it may be cited for its persuasive value.
The case reflects broader trends in healthcare enforcement, where federal agencies have recovered billions of dollars in recent years through False Claims Act settlements and judgments. The Justice Department's Healthcare Fraud Unit and various U.S. Attorney's offices across the country have made healthcare fraud prosecution a key priority.
Medicare fraud cases often involve complex billing schemes and require extensive investigation by federal agents and prosecutors. The government typically must prove that defendants knowingly submitted false claims, though the False Claims Act's knowledge standard can be satisfied by showing deliberate ignorance or reckless disregard for the truth.
The unanimous affirmance by the Eleventh Circuit suggests the evidence against Adams was substantial and that his legal challenges lacked merit. Appeals courts typically defer to jury findings on factual matters and only reverse when there are clear legal errors or insufficient evidence to support the verdict.
With the appeals court decision now final, Adams faces the prospect of paying the full judgment unless he seeks further review by the Supreme Court, though the high court accepts very few cases for review each year. The case demonstrates the significant financial and legal risks healthcare providers face when billing practices fall outside federal requirements and result in False Claims Act liability.
