Law360, New York ( April 5, 2013, 11:46 AM EDT) -- For the first time in the more than 60-year history of the statute, a federal appeals court has applied the Wartime Suspension of Limitations Act (WSLA), 18 U.S.C. § 3287, to a civil False Claims Act case. A World War II-era statute, the WSLA tolls any statute of limitations relating to an "offense" involving "fraud or attempted fraud" against the federal government "[w]hen the United States is at war." 18 U.S.C. § 3287. The suspension is effective until five years after the termination of hostilities." Id. In United States ex rel. Carter v. Halliburton Co., (4th Cir. Mar. 18, 2013), a divided panel of the U.S. Court of Appeals for the Fourth Circuit concluded that the WSLA tolled the six-year FCA statute of limitations, 31 U.S.C. § 3731(b)(1), for false claims alleged under a 2005 war zone contract....