The federal False Claims Act prohibits “knowingly” submitting a false claim.  It defines knowingly to mean actual knowledge, deliberate ignorance, or reckless disregard of truth or falsity.  (31 U.S.C. §3729(b)(1)(A).)  This decision holds that especially as read against the background of common law fraud which the False Claims Act builds on, the statutory definition of “knowingly” sets a standard governed by the defendant’s actual subjective belief.  If it is unclear whether a claim is legal or not, it does not matter what a reasonable person would conclude, liability is established if the defendant actually believed, even wrongly, that the claim was false.  Safeco Insurance Co. v. Burr (2007) 127 S.Ct. 2201 is not inconsistent.  It dealt with a different standard, “willfulness,” under a different statute with a different historical background.  Context matters in giving meaning to a word in a statute.