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United States, ex rel. Mark J. O'Connor, et al. v. USCC Wireless Investment, Inc., et al.

Paid petition · United States Court of Appeals for the District of Columbia Circuit, No. 23-7044 · judgment February 11, 2025


Certiorari denied · January 12, 2026
Pre-decision estimate: 16% cert probability (95% interval 9%–26%)

Before the decision, about 3.9× the 4.1% base rate. The model weighted this up for a federal-government petitioner, a D.C. Circuit decision below, and counsel with five or more prior petitions here, and down for a business respondent.

Questions presented

  1. Whether the D.C. Circuit erred by requiring plaintiffs to anticipate and negate in their complaint a False Claims Act affirmative defense, in direct conflict with Cunningham v. Cornell University, 145 S. Ct. 1020 (2025), and basic principles of civil procedure.

  2. Whether a False Claims Act plaintiff’s independent knowledge that prompts a multi-year fraud investigation “materially adds” to what is publicly disclosed under 31 U.S.C. § 3730(e)(4)(B), or whether it must be so substantial it is likely to prompt the government to intervene and prosecute the fraud, as the D.C. Circuit held, deepening a conflict among the federal courts of appeals.

Counsel of record

For petitioner
Daniel Hirotsu Woofter
Russell & Woofter LLC

For respondent
Kwaku Affawua Akowuah
Sidley Austin LLP

Case

Conference history
Distributed for 2 conferences

Linked docket
25A9

Proceedings

  1. Jan 12 2026
    Petition DENIED.
  2. Dec 10 2025
    DISTRIBUTED for Conference of 1/9/2026.
  3. Dec 10 2025
    Reply of petitioners United States, ex rel. Mark J. O'Connor, et al. filed. (Distributed)
  4. Nov 26 2025
    Brief of respondents USCC Wireless Investment, Inc., et al. in opposition filed.
  5. Oct 15 2025
    Motion to extend the time to file a response is granted and the time is extended to and including November 26, 2025, for all respondents.
  6. Oct 14 2025
    Motion to extend the time to file a response from October 27, 2025 to November 26, 2025, submitted to The Clerk.
  7. Sep 25 2025
    Response Requested. (Due October 27, 2025)
  8. Sep 17 2025
    DISTRIBUTED for Conference of 10/10/2025.
  9. Sep 09 2025
    Waiver of right of respondent Wireless Investment, Inc., et al. to respond filed.
  10. Sep 05 2025
    Petition for a writ of certiorari filed. (Response due October 9, 2025)
  11. Jul 02 2025
    Application (25A9) granted by The Chief Justice extending the time to file until September 5, 2025.
  12. Jun 27 2025
    Application (25A9) to extend the time to file a petition for a writ of certiorari from July 7, 2025 to September 5, 2025, submitted to The Chief Justice.