Fitzer v. Allergan, Inc.

CourtDistrict Court, D. Maryland
DecidedJanuary 15, 2025
Docket1:17-cv-00668
StatusUnknown

This text of Fitzer v. Allergan, Inc. (Fitzer v. Allergan, Inc.) is published on Counsel Stack Legal Research, covering District Court, D. Maryland primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Fitzer v. Allergan, Inc., (D. Md. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND

* UNITED STATES OF AMERICA * ex rel. MATTHEW A. FITZER, M.D., * * Plaintiffs, * v. * Civil Case No. 1:17-cv-00668-SAG * ALLERGAN, INC., et al. * * Defendants. * * * * * * * * * * * * * * * * MEMORANDUM OPINION

Relator Dr. Matthew Fitzer (“Relator”) filed this False Claims Act (“FCA”) lawsuit against Defendant Allergan, Inc. (“Allergan”) in 2013, alleging that Allergan’s LAP-BAND Surgeon Locator constituted a kickback to its listed surgeons. After multiple rounds of briefing, including one initial round of summary judgment briefing, this Court announced a four-factor causation standard and allowed the Parties to submit supplemental summary judgment briefing (and evidence) applying that standard on a surgery-by-surgery, claim-by-claim basis. ECF 343. Relator submitted supplemental evidence and, after a telephone conference, amendments to his supplemental submissions to address this Court’s questions for the Parties. ECF 361–64, 369, 374. Allergan has filed a renewed Motion for Summary Judgment applying the four-factor standard. ECF 381. Relator opposed the motion, ECF 389, and Allergan submitted a reply memorandum. ECF 396. No hearing is necessary. See Loc. R 105.6 (D. Md. 2023). For the reasons described below, Allergan’s motion will be granted in part and denied in part. The surgeries and claims remaining for trial are listed in an appendix to this opinion. I. DISCUSSION Recognizing that the Fourth Circuit has not yet opined on the appropriate causation standard for an Anti-Kickback Statute (“AKS”)-based FCA claim, this Court adopted the “middle of the road” approach taken by the Third Circuit in United States ex rel. Greenfield. v. Medco Health Solutions, Inc., 880 F.3d 89, 100 (3d Cir. 2018). ECF 353 at 5–6. Under the “middle of the

road” approach, “a kickback does not morph into a false claim unless a particular patient is exposed to an illegal recommendation or referral and a provider submits a claim for reimbursement pertaining to that patient.” Greenfield, 880 F.3d at 100. Applying that standard to this case, in a prior opinion this Court explained exactly what evidence Relator must adduce to create a genuine issue of material fact as to causation for a particular procedure and claim. ECF 353 at 8. The factors are: (1) that the surgeon was on the Locator at approximately the time of the surgery; (2) that the surgeon knew she1 was on the Locator at that time; (3) that the surgeon knew at that time that some prescription-based criteria existed to get on or remain on the Locator—in other words, that the surgeon recognized the need to perform more LAP-BAND operations to derive the benefit from

being on the Locator; and (4) that the surgeon then performed a LAP-BAND surgery and a Medicare claim ensued. ECF 353 at 8. This Court has recounted the facts of this long-enduring lawsuit numerous times, and most recently in its opinion denying the Parties’ first cross-motions for summary judgment. ECF 353. Here, the Court will address the facts relevant to causation, considered in the light most favorable to Relator as the non-moving party, applied to the four-factor test it has previously outlined.

1 For simplicity, this Court will use feminine singular pronouns for unnamed surgeons, recognizing that surgeons may be of any gender. Applying that test, Relator argues that 4,309 surgeries survive summary judgment, and Allergan argues that just 38 procedures survive. This Court will analyze the fourth factor, which appears to dispose of the largest number of procedures, first. This the Court will then discuss the factors for the three categories of surgeries as Allergan has divided them—"icon-period claims,” “interim-period claims”, and “quota-period

claims.” 1. LAP-BAND Surgeries Performed and Submitted to Medicare The fourth factor requires that Relator evidence a genuine issue of material fact as to whether each individual surgery was a LAP-BAND procedure and a claim was submitted to Medicare. Allergan argues that the vast majority of surgeries can be disposed of on this factor. a. LAP-BAND v. REALIZE Although the Centers for Medicare and Medicaid Services (“CMS”) collect data about the total number of bariatric procedures billed to CMS, because “both Realize and LAP-BAND implantations were submitted to CMS for reimbursement using the [same]…code,” it is

challenging to parse which procedures used LAP-BANDs. ECF 381-1. Everyone agrees that the 862 procedures for which Allergan possesses business reply card (“BRC”) data were LAP-BAND procedures, not REALIZE procedures. ECF 381-1 at 8–9; ECF 389 at 25–26. The parties diverge thereafter: Relator would add several other categories of procedures to the list, and Allergan argues that there is no other reliable indicator that a particular procedure used a LAP-BAND. Relator’s first argument relates to the “Ethicon spreadsheet,” which was produced in discovery by Ethicon Endo-Surgery, the company that sold the REALIZE band. Ethicon described the spreadsheet as showing “the names and attendees at training events related to REALIZE bands from January 1, 2007 to December 31, 2015.” ECF 362-100. Relator argues that the Ethicon spreadsheet constitutes a comprehensive list of surgeons trained to use the REALIZE band, and thus that any surgeon not on that spreadsheet could only have been performing LAP-BAND procedures. ECF 364 ¶ 14 (citing ECF 190-7). In addition, Relator argues that this Court should presume that any surgery performed prior to the date of a surgeon’s REALIZE training must have been a LAP-BAND procedure. With the addition of these procedures, Relator’s count would reach

3,353 eligible procedures. ECF 362-102. Allergan raises several problems with Relator’s methodology. First, and fundamentally, Allergan offers evidence that the Ethicon spreadsheet is not a comprehensive list of all surgeons qualified to implement REALIZE bands. Fifteen surgeons who were listed on Ethicon’s surgeon Locator on November 6, 2014, are not included anywhere on the Ethicon spreadsheet. ECF 381-1 at 11. 55 additional surgeons appeared on Ethicon’s Locator as REALIZE band surgeons as early as 2009, but never attended a training session and were not listed on the Ethicon spreadsheet. Id. Relator’s attempt to infer that surgeons absent from the Ethicon spreadsheet did not perform any REALIZE procedures lacks sufficient evidentiary support.

Allergan also argues that the Ethicon spreadsheet is inadmissible hearsay. Id. at 11 n.6. Relator rejoins that the spreadsheet is subject to the hearsay exception for business records. ECF 389 at 28. Relator does not apply the elements of either Rule 803(6) or Rule 803(7), and specifically fails to provide evidence that the spreadsheet was kept as a matter of regular practice, falling short of his burden to show that it is possible to put this information in admissible form. See Fed. R. Civ. P. 56(c)(2); Humphreys & Partners Architects, L.P. v. Lessard Designs, Inc., 790 F.3d 532, 538 (4th Cir. 2015). Moreover, the spreadsheet was created in response to a discovery request issued in this lawsuit, which would seem to undermine Relator’s assertion that it was created in the ordinary course of business. Even if it had been admissible, the substantive issues with the Ethicon spreadsheet render it an inappropriate basis for inferring that any particular surgeon did not perform REALIZE procedures. Without more, the Ethicon spreadsheet is insufficient to create a genuine issue of material fact.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cite This Page — Counsel Stack

Bluebook (online)
Fitzer v. Allergan, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/fitzer-v-allergan-inc-mdd-2025.