State Farm Fire & Casualty Co. v. United States, ex rel Rigsby
U.S. Supreme Court · decided December 6, 2016 · Supreme Court Database (Spaeth)
- Decided
- December 6, 2016
- Term
- October Term 2016
- Vote
- 8–0
- Majority author
- Justice Kennedy
- Issue area
- Economic Activity
- Disposition
- Affirmed
- Outcome
- Petitioning party lost
- Ideological direction
- Liberal
Opinion excerpt
Justice KENNEDY delivered the opinion of the Court. This case addresses the question of the proper remedy when there is a violation of the False Claims Act (FCA) requirement that certain complaints must be sealed for a limited time period. See 31 U.S.C. § 3730(b)(2). There are two questions presented before this Court. First, do any and all violations of the seal requirement mandate dismissal of a private party's complaint with prejudice? Second, if dismissal is not mandatory, did the District Court here abuse its discretion by declining to dismiss respondents' complaint? I A The FCA imposes civil liability on an individual who, inter alia, "knowingly presents ... a false or fraudulent claim for payment or approval" to the Federal Government. § 3729(a)(1)(A). Almost unique to the FCA are its qui tam enforcement provisions, which allow a private party known as a "relator" to bring an FCA action on behalf of the Government. § 3730(b)(1) ; Vermont Agency of Natural Resources v. United States ex rel. Stevens, 529 U.S. 765, 768, n. 1, 120 S.Ct. 1858, 146 L.Ed.2d 836 (2000) (listing three other qui tam statutes). The Attorney General retains the authority to intervene in a relator's ongoing action or to bring an FCA suit in the first instance. §§ 3730(a) -(b). This system is designed to benefit both the relator and the Government. A relator who initiates a meritorious qui tam suit…
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