DOJ Grants First Healthcare Declination Under New Corporate Enforcement Policy While Indicting Founder
On July 29, 2026, the Department of Justice (“DOJ”) announced that, consistent with Part I of DOJ’s Department-wide Corporate Enforcement and Voluntary Self-Disclosure Policy (“CEP”), it declined to prosecute Campus Eye Management Holdings LLC and its wholly owned subsidiary, Campus Eye Management LLC (collectively, “Campus Eye”), a management services organization that provided billing and other services to an optometry practice and ambulatory surgery center. DOJ had been investigating Campus Eye for alleged healthcare fraud, including illegal kickbacks. This is the first declination involving a healthcare company under the new, Department-wide CEP. And it is only the second healthcare fraud declination under any voluntary self-disclosure policy in DOJ history—the first being the HealthSun Health Plans, Inc. matter handled by the same team (i.e., the Health Care Fraud Unit) when they were part of the Criminal Division’s Fraud Section, prior to creation of the National Fraud Enforcement Division (“NFED”) earlier this year. Click here to read the full blog post.
DOJ Expands Trade Fraud Enforcement After $1 Billion Milestone
The U.S. Department of Justice and the Department of Homeland Security announced on July 14, 2026, that the Trade Fraud Task Force had surpassed $1 billion in criminal and civil recoveries, penalties, forfeitures, and publicly charged losses less than one year after its launch. The announcement confirms a fundamental shift in the federal government’s approach to customs and trade enforcement, reflecting increased emphasis on rigorous criminal prosecution and civil enforcement under the False Claims Act.
Sidley Secures Presidential Pardons for Two Clients
Sidley successfully assisted clients Joshua Davis and Aaron Rudolf in obtaining presidential pardons, providing extraordinary relief in connection with prior convictions under the Clean Air Act.
The firm represented Mr. Davis in securing his pardon following a single Clean Air Act violation. Sidley also represented Mr. Rudolf as co-counsel in obtaining his pardon for the same offense.
The pardons follow broader advocacy by Sidley on the scope and fairness of criminal enforcement under the Clean Air Act. In September 2025, Justin Savage testified before the U.S. House Committee on Oversight and Government Reform regarding the rise in these criminal prosecutions, the need for clear statutory authority and fair enforcement, and Mr. Davis’ and Mr. Rudolf’s cases.
