On May 19, 2025, Deputy Attorney General Todd Blanche issued a memorandum establishing a DOJ Civil Rights Fraud Initiative. The Initiative will use the False Claims Act (“FCA”) to “investigate and . . . pursue claims against any recipient of federal funds that knowingly violates federal civil rights laws.” Educational institutions, federal contractors, grantees, and other entities that receive federal funding should take note of the latest FCA Initiative. Similar FCA initiatives, such as those focused on collusion and cybersecurity fraud, have resulted in significant related FCA enforcement.Continue Reading Justice Department Establishes Civil Rights Fraud Initiative, Using False Claims Act to Target DEI

Terra White Fulham
Terra Fulham represents corporate and individual clients in complex litigations and investigations, with particular expertise in defending government contractors against allegations of fraud and False Claims Act violations. She has experience representing clients at all stages of internal and government investigations, including conducting witness interviews, managing government subpoena and CID responses, defending witnesses in government interviews, and advocating before government enforcement officials. She has represented clients in investigations and litigation brought under the False Claims Act, including matters alleging noncompliance with cybersecurity requirements, small business fraud, quality assurance deficiencies, conflicts of interest, and cost mischarging. Terra also has experience with suspension and debarment matters, representing entities in such proceedings to ensure their continued eligibility to participate in federal programs.
She has also represented clients in a variety of litigation matters during motions practice, discovery, and final hearings.
Terra also maintains an active pro bono practice, with an emphasis on immigration-related impact litigation.