MORRIS SHEPPARD ARNOLD, Circuit Judge.
Stanley L. Peters appeals from a summary judgment imposing liability on him for civil damages and penalties under the False Claims Act, 31 U.S.C. §§ 3729-3733 ("FCA"), on account of certain fraudulent acts for which he was previously indicted and convicted. Because we hold that this judgment does not constitute punishment under United States v. Halper,
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