UNITED STATES v. HALPER

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Case Basics
Docket No. 
87-1383
Petitioner 
Halper
Respondent 
United States
Advocates
(Argued the cause for the United States)
(Argued the cause as amicus curiae in support of the decision below)
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Facts of the Case 

Irwin Halper, the manager of a company that provided medical services to patients eligible for Medicare benefits, was charged and convicted in criminal court of submitting 65 separate false Medicare claims. He was sentenced to two years in prison and fined $5,000.

The United States then brought additional civil charges under the False Claims Act, which authorized it to collect $2000 for each offense in addition to attorney's fees and twice the damages sustained. In this case the actual damages were just $585, but because of the number of offenses the total penalty was more than $130,000. The District Court, however, ruled that the penalty was "entirely unrelated" to the government's actual damages and would therefore be a second punishment for the same offense, violating the Double Jeopardy Clause of the Fifth Amendment. The penalty was therefore limited to double the amount of actual damages and attorney's fees. The government appealed the decision directly to the U.S. Supreme Court.

Question 

Where the penalty authorized under the False Claims Act is "entirely unrelated" to the damages actually suffered by the government, does imposition of the penalty amount to a "punishment" governed by the Double Jeopardy Clause of the 5th Amendment?

Conclusion 
Decision: 9 votes for Halper, 0 vote(s) against
Legal provision: Double Jeopardy

Yes. Justice Harry Blackmun, on behalf of a unanimous Supreme Court, wrote that while previous cases had held penalties under the Act to be civil in nature, that did not foreclose the possibility of the penalty being so extreme and so unrelated to the actual damages as to constitute "punishment." Because Halper had already been jailed and fined, additional punishment in a separate proceeding would violate the Double Jeopardy Clause of the Fifth Amendment. The Court remanded the case to the District Court so that the government could challenge the original assessment of its attorney's fees.

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UNITED STATES v. HALPER. The Oyez Project at IIT Chicago-Kent College of Law. 19 June 2014. <http://www.oyez.org/cases/1980-1989/1988/1988_87_1383>.
UNITED STATES v. HALPER, The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/1980-1989/1988/1988_87_1383 (last visited June 19, 2014).
"UNITED STATES v. HALPER," The Oyez Project at IIT Chicago-Kent College of Law, accessed June 19, 2014, http://www.oyez.org/cases/1980-1989/1988/1988_87_1383.