Attorney Sarah M. Frazier

Sarah Frazier

Sarah Frazier


3704 Travis
Houston, Texas 77002-9550

Phone: 713-529-5622
Fax: 713-529-3785


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Practice Areas

Qui Tam Litigation
White Collar Defense
Commercial Litigation
Civil Litigation
Personal Injury


Sarah M. Frazier has a nationwide practice that includes qui tam suits representing whistleblowers, white collar criminal defense, and commercial law. She is currently pursuing several qui tam suits, many still under seal, on subjects ranging from war profiteering to Medicaid kickbacks to best price violations, pending in jurisdictions across the United States. Ms. Frazier was named a Texas Rising Star by her peers in 2007, 2008, 2009 and 2010 as published in Texas Monthly magazine. She lectures frequently on both qui tam and criminal law. Ms. Frazier recently presented a webinar entitled, “Prosecuting and Defending Qui Tam Cases Under the False Claims Act: What It Takes to be Successful,” sponsored by the Law Journal Press.

Joel Androphy and Sarah Frazier served as Program Directors for the American Bar Association's National False Claims and Qui Tam Trial Institute in Washington DC, from June 5-7, 2013. Joel and Sarah handled the jury selection, opening argument, and closing argument. To learn more about Joel and Sarah's participation in the Workshop, and phases of the "Trial" please view the False Claims Institute's Program Brochure.

Her experience includes:

  • With Joel Androphy and Rachel Grier, won a settlement with Frazier Masonry Corporation of Camarillo, California and other entities and individuals, who agreed to pay nearly $1.9 million to settle civil allegations that they conspired to defraud the United States in connection with military construction projects at Camp Lejeune in North Carolina and Camp Pendleton in California.
  • With Joel Androphy and Rachel Grier, won a settlement with Children's Physician Services of South Texas, Driscoll Genetic Services, Center for Genetic Services, and Radiology Associates, who agreed to pay $2.3 million to settle civil allegations that they engaged in false or fraudulent conduct by double-billing the Texas Medicaid program, TRICARE, and the Federal Employee Health Benefit Program for the professional reading and interpretation of genetic ultrasounds.
  • With Joel Androphy won an acquittal of a U.S. executive accused of Foreign Corrupt Practices Act (FCPA) violations and payments made to officials of a Mexican state-owned electric utility on January 18, 2012, after a jury trial in Houston federal court. More Info.
  • With Joel Androphy, obtained 4 acquittals of a prominent cancer doctor accused of insurance fraud by four major insurance companies. The trial involved billing for the drug Herceptin.
  • With Joel Androphy and Kathryn Nelson, won a settlement with American Grocers in a qui tam action in United States District Court. The case involved the alteration of expiration dates on food products sent to American troops in the Middle East.
  • With Joel Androphy, represented one of the nine whistleblowers and won a settlement with Eli Lilly in a civil qui tam action in U.S. District Court. The case involved off-label marketing of the drug Zyprexa. This civil settlement netted the government and all whistleblowers about $750 million. The government will also receive an additional $600 million in criminal fines.
  • One of two lead attorneys for a $2 million settlement of a qui tam case involving rampant fraudulent Medicare billing by a supplier of durable medical equipment. Settlement was accomplished without Department of Justice intervention and despite company’s plummeting stock prices.
  • Represented physician in federal criminal misbranding prosecution tried to jury twice, resulting first in a hung jury, then in a conviction overturned on appeal.
  • Successfully argued to full panel of Texas Court of Criminal Appeals for reversal of district court order denying DNA testing in a capital case.
  • Defended Houston business in commercial litigation concerning commissions and proceeds from sale of business, resulting in award of complete summary judgment to defendant, upheld on appeal.
  • Represented individual in pre-indictment federal anti-trust investigation, resulting in Department of Justice decision not to pursue criminal charges against client.
  • Represented international energy company in commercial dispute regarding business interruption at a gasification plant, resulting in summary judgment and ultimately dismissal of suit.
  • Represented international beer brewer in a commercial dispute over a putative brewing contract, handling mediation that resulted in favorable settlement.
  • Defended international energy company in royalty dispute, drafting summary judgment briefing that led to a “walk away” resolution.

Before joining Berg & Androphy, Ms. Frazier was associated with international law firm King & Spalding LLP, where she worked primarily on complex commercial cases, including tort and energy-related litigation.

Education and Judicial Clerkship

  • Vanderbilt University College of Law, Nashville, Tennessee
    J.D. Doctor of Jurisprudence, 1999
    Vanderbilt Journal of Transnational Law, Research Editor
  • Haverford College, Haverford, Pennsylvania
    B.A., Bachelor of Arts, Religion, 1994
  • Clerk to the Honorable Terrence W. Boyle, United States District Court, Eastern District of North Carolina, 1999-2000

Bar Admissions


Federal Criminal White Collar Appellate Update, The Appellate Advocate, State Bar of Texas Appellate Section Update, 2007-2012

Note, “Liberty of Expression in Ireland and the Need for a Constitutional Law of Defamation” 32 J. Vanderbilt Journal of Transnational Law 391 (March 1999).


Presentations & Seminars

  • Panelist, "Dealing with Whistleblowers in Internal Investigations and Related Proceedings," at LEGAL RISKS PRESENTED BY THE ROGUE EMPLOYEE, ABA Commercial and Business Litigation Committee/Regional CLE, Philadelphia, PA, February 7, 2014
  • Repeat Guest Lecturer on Government Procurement Fraud, Course on White Collar Practice, University of
    Alabama School of Law, 2012-­2014
  • "Criminal Law Issues in Business Litigation," presented at Business Disputes 2013, TexasBar CLE, Dallas, Texas, September 13, 2013
  • Served as Program Director for the ABA's National False Claims and Qui Tam Trial Institute in Washington DC, from June 5-7, 2013
  • "Minimizing Whistleblower Exposure Through Decisive Internal Action: What Companies Can Learn From the Experiences of the Plaintiffs' Bar," presented at American Conference Institute's 16th FCPA Boot Camp, San Francisco, CA, October 2, 2012
  • "The Trial of a Foreign Corrupt Practices Case," Houston Bar Association Securities Law Section, February 14, 2012