Audinot v. United States

How later courts describe this case

• holding that the Double Jeopardy Clause may be triggered when a “civil penalty ... rose to the level of criminal punishment because of the lack of rational relation to the Government’s loss”
• assessment of $1,791,100 in civil penalties based upon same conduct as criminal proceedings in civil action for filing false medicare claims remanded to the district court for a Halper analysis
• order of proceedings, civil and criminal, does not effect double jeopardy application
• the Halper principle applies whether civil penalty or criminal punishment comes first