On March 18, 2013, the Fourth Circuit issued a ruling in U.S. ex rel. Carter v. Halliburton Co. --- F.3d ----, 2013 WL 1092732 (4th Cir. 2013), that the usual 6-year statute of limitations under the False Claims Act is tolled during wartime under the relatively unknown Wartime Suspension of Limitations Act ("WSLA"), 18 U.S.C. § 3287. Id. at *4-8. In that case, the Fourth Circuit held that the relator's claim was tolled because the nation is currently at war and the WLSA's tolling provisions applied to the qui tam case at issue. Id. As Judge G. Steven Agee pointed out in his dissent, this allows the relator Carter until at least 2019 to file his FCA claim, "nearly fourteen years after his claims accrued." Id. at *21 (Agee, J., dissenting).

How far this decision will go is unclear. Carter involved a government contractor providing war-related services to the government. Although there are good arguments that the holding should be limited to these facts, we could imagine creative relators' counsel attempting to argue that a similar holding should apply with respect to, for instance, GI funds.