On March 24, 2026, the U.S. District Court for the Northern District of Illinois decided that federal grantees can challenge grant terminations by the Administration if at the time of termination the grantees were compliant with Administration policies that were in place at the time the grant was awarded, as opposed to new rules or policies subsequently imposed by the Trump Administration. This decision could aid federal contractors and grantees in their legal challenges to the numerous contract and grant terminations, which have occurred since January 2025, based on alleged failure of the contracts or grants to align with or effectuate new Administration programs, policies, goals, and/or priorities, including, but not limited to, those relating to diversity, equity and inclusion (DEI) programs and policies. 

The annual False Claims Act (FCA) recovery statistics issued by the U.S. Department of Justice (DOJ) for Fiscal Year 2025 represent the highest single-year recovery in FCA history, underscoring that the FCA remains one of the government’s most effective tools for combating frauds involving federal funds. Winston attorneys outline expectations for FCA enforcement in 2026 and beyond based on an analysis of FY 2025 FCA activity and the priorities and goals of the current administration.