Justin M. Lugar

Drawing on his background as both public servant and private practitioner, Justin represents clients facing all manner of government investigations, including grand jury investigations, congressional investigations, administrative investigations, regulatory inquiries, False Claims Act/whistleblower investigations, RFIs, civil rights investigations, and Inspectors General investigations.

Prior to joining Woods Rogers, Justin served as an Assistant U.S. Attorney in the Western District of Virginia, where he led the Affirmative Civil Enforcement team in managing dozens of active fraud investigations, many of which had parallel criminal investigations under the False Claims Act and various state analog statutes.

Justin also served as the Department of Justice’s Civil Health Care Fraud Coordinator, ACE coordinator, and Civil Rights Coordinator for the Western District of Virginia. Justin was recently recognized by the DEA for his efforts in enforcing the Controlled Substances Act, leading to the largest fine assessed against a hospital system in the United States at the time. 

During his time as a federal prosecutor, Justin led investigations involving numerous state and federal agency partners including FBI, DEA, HHS, DCIS, NCIS, DHS, Treasury, IRS, DOE, FDA, DOL, ICE, DOT, CMS, USAC, SBA, NAMFCU, VA MFCU, USDA, USN, ATF, U.S. Park Service, U.S. Fish & Wildlife, , USCIS, DCAA, DLA, DOD, DOI, VA DOC, US BOP, FHA, HUD, USPS, TVA, TSA, CBP, and VSP.    

Justin started his legal career as an associate at Wilmer Hale in London, where he conducted international investigations in the UK, Switzerland, Hong Kong, and Singapore as well as represented several Fortune 100 companies in international commercial arbitrations. Justin returned to Roanoke in 2012 where he practiced as a partner at Gentry Locke before joining the Department of Justice.

A religious studies major in college, Justin has traveled extensively throughout Asia and at one time, lived at a Tibetan Buddhist Monastery in Kathmandu, Nepal. Upon graduation from law school, he moved to London, UK, where he earned his LLM in International Dispute Resolution (South Asia focus) and was an associate at Wilmer Hale. As an associate in the firm’s International Arbitration Group and Investigations Group, Justin conducted on-site investigations in Geneva, Zurich, Hong Kong, and Singapore.

Healthcare and Life Sciences

• Led numerous investigations regarding Stark Act and Anti-Kickback Statute allegations with exposure of over $125m.
• Led multi-jurisdictional investigation into Medicare Part D fraud of over $40m.
• Led multi-jurisdictional investigation involving Medicaid home healthcare fraud with damages exceeding $38m.
• Led several investigations into mental and behavioral health service providers.
• Led investigation into fraud related to Medicare, Medicaid, and Tricare payments for compounded prescriptions.
• Led investigations into numerous COVID-related fraud schemes, including PPP loan schemes and allegations of billing fraud to HRSA related to COVID testing and treatment claims.
• Led investigations into upcoding, worthless services, “incident to” billing, medical transport, and fraudulent DME sales.
• Led investigations into biologicals and DME testing and grant fraud.
• Led numerous investigations into off-label marketing allegations as well as misbranding.
• Led several investigations into potential “pill mill” operations, including physicians and pharmacies.
• Led investigations into various billing schemes for the treatment of opioid use disorder, including counseling-related claims.
• Successfully obtained 42 CFR Part 2 Orders relating to investigations involving substance abuse treatment records.
• Successfully defended mental and behavioral health provider in multi-year federal investigation.

Food and Drug

• Represented Stewart Parnell, CEO of Peanut Corporation of America, in six-week federal jury trial in the Middle District of Georgia related to peanut salmonella outbreak and largest food recall in U.S. history.
• Investigated introduction of introduction of adulterated food and drugs into interstate commerce under the FDCA.
• Led investigations into misbranding and off-label marketing promotions by pharmaceutical companies.
• Defended manufacturers and marketers of OUD pharmaceuticals from allegations of misbranding, off-label marketing, and other Medicare/Medicaid fraud allegations.
• Led investigations into unlawful dispensing and diversion of controlled substances, including DEA-222 fraud.

Government Contracting and Procurement Fraud

• Lead counsel in 14-day federal jury trial related to sale of armored vehicles to the Joint Contracting Command in Iraq.
• Represented former USN Seal accused of espionage related to ITAR violations; resolved with plea to one misdemeanor count of mishandling classified information; held TS/SCI clearance for case.
• Led numerous investigations into government contract fraud in the following industries:
  • Textiles and fabrics
  • Military aircraft components
  • Armored vehicles
  • Executive security/training
  • Energy Savings Performance Contracts (ESPCs)
  • Tactical gear
  • Buy American Act violations
  • SBA program certifications

Environmental

• Representation of chemical company accused of numerous Clean Water Act violations—resulted in corporate plea and fine, and no individual prosecutions.
• Led enforcement action related to sale of a superfund site.
• Successfully defended Council of Environmental Quality in relation to nationwide injunction bid to halt agency rulemaking relating to NEPA guidelines.

Financial Services/Tax

• Led multi-jurisdictional FIRREA investigation into mortgage-related services.
• Part of investigative team in Geneva, Hong Kong, Singapore related to U.S.-held Swiss bank accounts.
• Lead defense counsel in numerous tax fraud investigations.

Public Corruption

• Counsel to former state senator relating to allegations of misconduct/bribery.
• Counsel to several corporate and individual targets/subjects in relation to laying of fiber optic cables for a public/private utility.
• Counsel to former state representative in relation to SBA 8(a) fraud.

Civil Rights

• Led more than a dozen civil rights investigations into potential ADA violations, as well as RLUIPA matters, including healthcare facilities, corrections institutions, voting centers, and financial institutions.
• Successfully defended numerous individual accused of misconduct under Title IX before a variety of state educational institutions.

Education

SOAS University of London, LLM, with distinction

Liberty University School of Law, J.D.

University of Virginia, B.A.

Admissions

Virginia

U.S. Court of Appeals, Fourth Circuit

U.S. Court of Appeals, Eleventh Circuit

U.S. District Court, Western District of Virginia

U.S. District Court, Eastern District of Virginia

• American Bar Association
• Federal Bar Association
• Virginia Bar Association