Photo of Christopher Carusone, Co-Chair

Christopher D. Carusone is a Partner in the Harrisburg office of Cohen Seglias Pallas Greenhall & Furman PC, where he serves as Chair of the Government Law & Regulatory Affairs and Energy & Utilities Groups, as well as Co-Chair of the Internal Investigations Group. With twenty years of experience in the public sector, Chris concentrates his practice in the areas of government law and regulatory affairs, internal investigations, energy and utilities, labor and employment law, and commercial litigation.

This article originally appeared in The Legal Intelligencer on April 25, 2017

IN-HOUSE COUNSEL

Since taking office on Jan. 20, President Donald Trump has ­issued two executive orders designed to implement what his chief strategist Stephen K. Bannon has described as “deconstruction of the administrative state.” While ­”deconstruction” is perhaps too strong a word for what the administration has proposed thus far, corporate counsel would be well advised to keep abreast of the developments of the regulatory reform effort in Washington to prepare their clients to take advantage of this important, limited-time opportunity. Continue Reading Corporate Counsel and Trump’s Regulatory Reform Agenda

This article originally appeared in The Legal Intelligencer on February 21, 2017

IN-HOUSE COUNSEL

Last fall, the U.S. Sentencing Commission published the results of its study on the federal ­prosecution of corporations and other organizational ­offenders. The results of that study, based on sentencing data for the calendar year 2015, says much about the types of organizations and offenses that are most likely at risk for federal prosecution and how corporate counsel can reduce the risk of corporate criminal liability in the new year.  Continue Reading Reducing the Risk of Corporate Criminal Liability

This article originally appeared in Corporate Counsel on January 1, 2017.

Much has been written over the last sixteen months interpreting the shift in U.S. Justice Department policy placing greater emphasis on individual accountability for corporate wrongdoing in federal civil and criminal enforcement proceedings.  Apparently not all of it was accurate.  In what has become known as the “Yates Memo” issued on September 9, 2015, U.S. Deputy Attorney General Sally Quillian Yates outlined six steps to strengthen the Department’s pursuit of individual wrongdoing in corporate investigations:  Continue Reading Five Common Misconceptions About The Yates Memo

This article originally appeared in The Legal Intelligencer

In-House Counsel

Countdown FiveFor attorneys who routinely litigate matters adverse to federal and state government agencies, sometimes ­referred to as government and regulatory law, the trend has been easy to see. Over the last half century or so, the U.S. Supreme Court has gradually expanded the degree of deference traditionally afforded to the rules and adjudications of administrative ­agencies. This has included not only ­deference to legislative rules resting on legislatively conferred rulemaking powers, referred to as Chevron deference, but also to interpretive rules created by an agency based on its specialized role and expertise, referred to as Skidmore deference. Continue Reading Five Crucial Mistakes to Avoid During PA Administrative Litigation

This article originally appeared in Corporate Counsel

Part One: The Changing Corporate Counsel Landscape

Gavel with Check List ClipboardIn this renewed era of individual responsibility for corporate malfeasance, corporate counsel would be well advised to help protect themselves from personal liability by taking six steps of their own when notified of allegations of wrongdoing within the company.

Continue Reading Part 2: Six Steps Corporate Counsel Must Take to Protect Themselves During Government Investigations

This article originally appeared in Corporate Counsel

internal-investigationFive years ago, the U.S. Justice Department announced that it had charged GlaxoSmithKline Vice President and Associate General Counsel Lauren Stevens with two counts of obstruction of justice and four counts of making false statements to the Food and Drug Administration (FDA). At issue were allegations that Stevens had sent a series of letters to the FDA denying that the company had promoted its drug Wellbutrin for off-label uses and that she failed to turn over evidence to the contrary, including various slides used by physicians paid by the company to promote the drug’s off-label use.  

Continue Reading Part 1: The Changing Corporate Counsel Landscape