In San Francisco Unified School District ex. rel. Contreras v. First Student, Inc., No. A136986, Cal. Court App. (1st Dist. Mar. 11, 2014), the court held that “a vendor impliedly certifies compliance with express contractual requirements when it bills a public agency for providing goods or services.” In other words, the mere submission of an invoice exposes a government contractor to CFCA liability if it knowingly breached a material contract term.
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