(April 27, 2016, 4:21 PM EDT) -- RICHMOND, Va. — The Fourth Circuit U.S. Court of Appeals on April 26 vacated dismissal of a False Claims Act (FCA) lawsuit involving a pain patch because a district court judge did not first consider whether she had jurisdiction under the first-to-file or public disclosure rules (United States ex rel. Jerome Palmieri v. Alpharma, Inc., et al., No. 14-1388, 4th Cir.; 2016 U.S. App. LEXIS 7525)....