Sarah M. Frazier


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. She lectures frequently on both qui tam and criminal law.

Ms. Frazier taught a course on qui tam/Dodd-Frank litigation at the University of Houston Law Center in the spring of 2012. In 2011, Ms. Frazier successfully defended John O’Shea of FCPA charges related to a contract by ABB to provide a smart grid to a Mexican utility, winning acquittal on all charges at trial. ABB had previously pled guilty. Ms. Frazier was named a Texas Rising Star by her peers in 2007, 2008, 2009 and 2010 as published in Texas Monthly magazine.

Joel Androphy and Sarah Frazier served as Program Directors for the American Bar Association’s 1st and 2nd National False Claims and Qui Tam Trial Institute in Washington, D.C., from June 5-7, 2013 and in Denver, Colorado, from June 3-5, 2015. Mr. Androphy and Ms. Frazier have handled the jury selection, opening argument, direct examination, and closing argument at these events. Ms. Frazier co-wrote the fact pattern for the first Trial Institute.

Representative Matters

  • 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 and Rachel Grier, won a settlement with Baylor University Medical Center, Baylor Health Care System, and HealthTexas Provider Network (collectively Baylor) in a qui tam action in the United States District Court. Baylor agreed to settle civil charges that they engaged in false or fraudulent conduct by improperly billing federal healthcare programs for robotic stereotactic treatment delivery without corroboration of direct physician supervision and overbilling for services associated with stereotactic procedures without the necessary documentation in the medical record or as duplicative claims for services already performed and paid in conjunction with other services. The settlement netted the clients and government approximately $880,000.
  • 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.
  • With Joel Androphy, obtained 4 acquittals of a prominent oncologist 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.
  • Whistleblower’s Complaint’s Leads Bering Straits Technical Services, L.L.C. and Bering Straits Native Corporation to Pay $2 Million to Settle Civil Fraud ChargesBering Straits Technical Services, L.L.C. and Bering Straits Native Corporation have agreed to pay $2 million to settle civil charges involving alleged violations of the False Claims Act. The settlement was finalized April 26, 2016, without an admission of liability… Read More


  • J.D., Vanderbilt University College of Law
  • B.A., Haverford College


Law Clerk to the Honorable Terrence W. Boyle, United States District Court for the Eastern District of North Carolina, 1999-2000


  • Oral Argument Held In Jackson / Ruehlen Challenge, FCPA Professor (Dec. 10, 2012),
  • 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 and Seminars

  • Speaker, “Enforcement and Trial of a Foreign Corrupt Practices Act (FCPA) Case,” State Bar of Texas, International Law Section, “Nuts & Bolts” of International Law, May 29, 2015.
  • Speaker, “Adventures in Fraud—An Introduction to the Fundamentals of Fraud and Abuse Enforcement,” ABA Health Law Section, Emerging Issues in Healthcare Law, Lake Buena Vista, Florida, March 4, 2015.
  • Speaker, “Dealing with Whistleblowers in Internal Investigations and Related Proceedings,” Legal Risks Presented By The Rogue Employee, ABA Commercial and Business Litigation Committee/Regional CLE, Philadelphia, PA, February 7, 2014.
  • Guest Lecturer on Government Procurement Fraud, Course on White Collar Practice, University of Alabama School of Law, 2012-2014.
  • Speaker, “Obtaining and Using Discovery from the Government,” National False Claims Act and Qui Tam Trial Institute, Washington, D.C., June 13-15, 2013.
  • Speaker, “Criminal Law Issues in Business Litigation,” Business Disputes 2013, Texas Bar CLE, Dallas, Texas, September 13, 2013.
  • Program Director, 1st and 2nd ABA National False Claims Act and Qui Tam Trial Institute, Washington, D.C., June 5-7, 2013, Denver, CO, June 3-5, 2015.
  • Speaker, “Minimizing Whistleblower Exposure Through Decisive Internal Action: What Companies Can Learn From the Experiences of the Plaintiffs’ Bar,” American Conference Institute, 16th FCPA Boot Camp, San Francisco, CA, October 2, 2012.
  • Speaker, “The Trial of a Foreign Corrupt Practices Case,” Houston Bar Association, Securities Law Section, February 14, 2012.
  • Speaker, “The Greatest Pitfall of All: How to Avoid Subjecting Your Client to Criminal Prosecution,” University of Texas UTCLE, 6th Annual Consumer Bankruptcy Practice, August 13, 2010, Galveston, TX.
  • Speaker (Webinar), “Prosecuting and Defending Qui Tam Cases Under the False Claims Act: What It Takes to be Successful,” Law Journal Newsletters and Webinar, November 11, 2008.

Associations and Honors

  • Association of Women Attorneys, Judicial Endorsement Committee, 2004 & 2014
  • American Bar Association, Health Law Section
    • Chair, Healthcare Litigation and Risk Management, 2016-2017

    • Vice Chair, Emerging Issues in Healthcare Law, 2014-2015

    • Vice Chair, Healthcare Litigation & Risk Management, 2014-2016

  • Texas Monthly, “Rising Star,” 2007, 2008, 2009 & 2010
  • King & Spalding Pro Bono Service Award, 2002 & 2003


  • Texas
  • Georgia
  • U.S. Court of Appeals, Fifth Circuit
  • U.S. District Court, Southern District of Texas
  • U.S. District Court, Eastern District of Texas