Recent False Claims Act Decisions

 

 

I.       STATUTORY INTERPRETATIONS

 

A.     Section 3729(a)(7) Definition of “Obligation”

 

 

U.S. ex rel. Marcy v. Rowan Cos., Inc., 2008 WL 588745 (5th Cir. Mar. 5, 2008)

Relator brought an FCA and a reverse FCA action against offshore drilling companies, alleging the companies failed to disclose their illegal dumping activity in statutorily required reports, so as to avoid paying civil fines under applicable federal statutes. The Fifth Circuit, in affirming a lower court’s dismissal of the relator’s § 3729(a)(2) claims, found that the defendants’ statutory requirements to report their illegal dumping were not “material” to the defendants’ lease with the federal government, since compliance with those statutory requirements was not a prerequisite to continuation of the lease agreement. The court of appeals, relying on earlier precedent, also affirmed the dismissal of § 3729(a)(7) reverse FCA claims, for the “obligation” to pay the fines or penalties was not a sufficiently “fixed obligation,” but was instead “contingent” upon the government’s prosecutorial discretion.

 

Relator alleged that his former employer – a group of offshore drilling companies – instructed him to illegally dump hazardous materials into the Gulf of Mexico, that they intentionally failed to report this activity as is required by federal law, and that they intentionally omitted a record of these discharges from their statutorily required reports.  As a result, the realtor alleged, the companies avoided paying civil fines and other penalties under several federal statutes.   The relator filed a lawsuit against the drilling companies, alleging, among other things, violations of the False Claims Act, including violations of section 3729(a)(2) (making a false record or statement to get a false claim paid by the government) and section 3729(a)(7) (using a false record or statement to avoid an obligation to pay money to the government).  The defendants moved to dismiss the complaint, alleging that the relator failed to state a claim under the False Claims Act and that the relator did not plead the False Claims Act counts with sufficient particularity to satisfy the requirements of Federal Rule of Civil Procedure 9(b).  The U.S. District Court for the Eastern District of Louisiana did not reach the Rule 9(b) question, but nonetheless dismissed the False Claims Act counts, holding that the relator failed to state a claim under the False Claims Act.  The relator appealed and the 5th Circuit affirmed the district court’s ruling.

 

Section 3729(a)(2) Claim Was Properly Dismissed

The Fifth Circuit affirmed the lower court’s ruling, dismissing the section 3729(a)(2) claim.  The court found that the defendants, pursuant to a lease contract, did not request or demand payment from the United States, but rather, were extracting natural resources – oil – that belonged to the United States.  However, the relator argued that the illegal dumping necessarily violated the lease, and since the defendants failed to report their illegal dumping, they impliedly certified compliance with the lease, and as received the benefit of being able to continue to take government property as provided by the lease.  The court declined to rule on whether the defendants made a claim to the government for payment by impliedly certifying compliance with the lease.  Instead, relying on its prior decision in U.S. v. Southland Management Corp., 326 F.3d 669 (5th Cir. 2003), the Fifth Circuit affirmed the dismissal of this claim because it found that the defendants’ statutory requirements to report their illegal dumping were not material to the defendants’ lease with the United States, since compliance with those statutory requirements was not a prerequisite to continuation of the lease agreement. 

Reverse False Claims Act Claim Was Properly Dismissed

With respect to the reverse False Claims Act claim, the court affirmed the lower court’s dismissal.  The 5th Circuit, relying on its precedent in U.S. ex rel. Bain v. Georgia Gulf Corp., 386 F.3d 648 (5th Cir. 2004), ruled that any obligation the defendants may have had to pay fine and/or penalties to the U.S. government were potential and contingent, since, even if the government was aware of the illegal dumping, it still would have had to choose whether or not to impose any penalty against the defendants.  In addition, the court noted that any potential obligation to pay the government arose from statutory provisions – the lease agreement did not impose upon the defendants any obligations to pay money to the government.  Thus, quoting its decision in Bain, the court held that the relator did not state a claim under section 3729(a)(7), since the potential obligation to pay the government did not “arise out of an economic relationship between the government and the defendant (such as a lease or contract or the like) under which the government provides some benefit to the defendant wholly or partially in exchange for an agreed or expected payment or transfer of property (or on behalf of) the defendant to (or for the economic benefit of) the government.”  Ultimately, the court held that “[a]ll polluters face the prospect of liability for violations of environmental laws, regardless of whether they contract with the federal government or not.  If such violations were enough to create a reverse False Claims Act claim, it would broaden the scope of the Act far beyond present interpretations.”

 

Relator’s Motion To Amend His Complaint Was Properly Denied

The court of appeals also noted that after the district court dismissed the relator’s False Claims Act claims, the relator moved to amend his complaint, in order to add allegations that the Department of Justice would seek indictments against at least one of the defendants after investigating the relator’s allegations and that one of the defendants had agreed to plead guilty to a felony.  The district court denied that motion.  The Fifth Circuit affirmed that ruling, holding that “[t]he relevant time for evaluating the nature of Defendants’ obligation to pay is when they made or used the false statements. . . The government’s pursuit of charges against individual Defendants occurred well after the false certifications alleged by Marcy in the complaint.  Accordingly, the facts Marcy wished to add would not have assisted him in stating a reverse False Claims Act claim.

 

 

 

 

 

B.     Section 3729(a)(7) Calculating Damages

 

 

Un ited States v. Rogan, 2008 WL 442413 (7th Cir. Feb. 20, 2008)

 

The federal government brought an FCA action against a hospital administrator, alleging the administrator conspired with others to defraud the Medicare and Medicaid systems by concealing referrals that violated the Stark and Anti-Kickback Acts. After an Illinois district court entered judgment of $64 million for the government, the defendant-administrator appealed the decision. In affirming the decision, the Seventh Circuit ruled that the defendants’ statements were materially false under the FCA, for the statements were “capable of influencing” a government official. The court of appeals rejected the administrator-defendant’s argument that “materiality” could only be established by having a federal employee testify that the government was sure to enforce the underlying laws. Moreover, noting that Medicare and Medicaid payments are conditioned on providers not violating the Stark and Anti-Kickback Acts, the Seventh Circuit agreed with the government that all of the violative claims alleged in the case should be paid back trebled to the government. Lastly, while not opining on the question of whether the Eighth Amendment’s Excessive Fines Clause actually applies to civil FCA actions, the court of appeals determined that the $64 million judgment was not at level of being “grossly excessive,” for it was less than four times the actual damages and was well within the single digit level the Supreme Court found acceptable in State Farm Mutual Automotive Insurance Co. v. Campbell, 538 U.S. 408 (2003). 

 

The federal government successfully obtained a $64 million judgment against Peter Rogan, a former hospital administrator, who conspired with others to defraud the Medicare and Medicaid systems by concealing patient referrals that violated the Stark and Anti-Kickback Acts. Rogan appealed the decision to the Seventh Circuit.

 

Testimony of Government Official Is Not Necessary To Establish “Materiality”

 

Rogan argued that the federal government failed to introduce sufficient evidence that the underlying claims were “materially” false. According to Rogan, the government could have only satisfied the “materiality element” by having a federal government employee testify that it would not have paid the claims if he knew the providers were violating the Stark and Anti-Kickback Acts.

 

In rejecting Rogan’s argument, the Seventh Circuit stressed that “materiality” is established under the FCA by merely showing that the false claims were “capable” of influencing the government’s decision to pay. In turn, testimony from a claims-processing officer along the lines of “I follow the law” is not required. Instead, “materiality” is an objective standard, which, in this case, is dictated by the language of the Stark and Anti-Kickback Acts. The fact that  “overworked, harried, or inattentive disbursing officers” failed to reject the claims has no baring on whether or not the claims were “materially” false.

 

“Reliance Element” Satisfied

 

Rogan countered that the federal government did not actually “rely” on his omissions. While seeming to agree for the first time that “reliance” is an element into the FCA, the Seventh Circuit ruled that this was easy to show in this case, for the truth would have revealed that the reimbursements were illegal. Again, the court stressed that a government employee was not needed to testify that illegal claims would not have been paid.

 

Single Damages Are Entire Amount Paid By The Government for Stark-Violative Claims

 

Then, the court turned its attention to damages. Rogan maintained that even though they may have been violating the Stark Act when they submitted reimbursement claims to Medicare, the patients still received medical care, so there were not actual monetary damages to the government. The court of appeals, in soundly rejecting this limited reading of the Act, noted that when the government pays Medicare claims, it attaches certain conditions. The court reduced the inquiry to a simple, pithy statement: “When the conditions are not satisfied, nothing is due.” Accordingly, the Seventh Circuit ruled that nothing was due to Rogan for his violative claims, so he was liable for three times the entire amount paid under the 1,812 false claims. The final calculation came out to $64 million.

 

Court Refuses To Entertain Defendant’s Eighth Amendment Arguments

 

Rogan countered that this amount violated the Eighth Amendment’s Excessive Fines Clause. As an initial matter, the court of appeals stressed that it was far from clear whether the Excessive Fines Clause even applies to civil actions under the False Claims Act. Indeed, the U.S. Supreme Court has recently distanced itself from even considering the Act punitive. For example, in Hudson v. United States, 522 U.S. 93 (1997), the Court overruled United States v. Halper, 490 U.S. 435 (1989), and held that penalties under the False Claims Act are not criminal punishment for the purpose of the Fifth Amendment’s Double Jeopardy Clause. This reversal alone raised serious questions for the court of appeals over whether the Excessive Fines Clause was also inapplicable.

 

However, the Seventh Circuit decided that this issue was not germane in the case at bar, for Rogan had failed to raise an excessive-fines argument in the district court, and there is no general doctrine of plain-error review in civil cases. Moreover, because Rogan persuaded the lower court to exclude certain evidence that was necessary to assess “excessiveness,” the Seventh Circuit determined that the record was unsuitable to even resolve his constitutional argument. Lastly, the final $64 million judgment was less than four times the actual damages, which is well within the single-digit level found acceptable in State Farm Mutual Automobile Insurance Co. v. Campbell, 538 U.S. 408 (2003). Indeed, given the egregious facts of this case and the state of the record, the court of appeals ended by stating, “[F]or all we can tell, Rogan’s penalty may be too low.”

 

 

 

 

 

U.S. ex rel. Longhi v. Lithium Power Tech., Inc.,530 F. Supp. 2d 888 (S.D. Tex. 2008)

 

Relator filed suit against a technology company, alleging that the company violated the False Claims Act by making false statements and fraudulently inducing the Department of Defense to accept its contract proposals.  The relator further alleged that every invoice from the company under those contracts was false.  The district court granted summary judgment in favor of the relator, finding the company liable.  The court then turned to the question of the amount of damages sustained by the government and held that the government's actual damages amounted to three times the full amount paid on each of the contracts.  Finally, the court determined that the defendant's civil penalty amounted to one forfeiture for each of the four contracts, and assessed the maximum penalty for each forfeiture.

 

Alfred Longhi, a relator, filed a qui tam action in the District Court for the Southern District of Texas against Lithium Power Technologies, Inc. and two individual defendants, alleging violations of sections 3729(a)(1) and (a)(2) of the False Claims Act.  Longhi's complaint alleged that the defendants fraudulently induced the Department of Defense's Small Business Innovation Research Program to accept four contract proposals to fund the defendants' development of special batteries that could later be marketed to the government.  The complaint alleged that the defendants accomplished this fraud by misrepresenting their level of experience and facilities.  The district court granted summary judgment in the relator's favor, finding that every invoice under the four contracts that the defendants submitted constituted a false claim.  The court was then faced with the challenge of determining the damages and civil penalty to be assessed against the defendants.

 

Actual Damages

 

The court first noted that the False Claims Act provides for the assessment against a liable defendant of "3 times the amount of damages which the government sustains" because of the defendant's actions.  However, the court stated that it could not locate any specific standard for calculating damages under the False Claims Act, and that there appeared to be a dearth of caselaw on the issue of calculating damages for liability based on a fraudulently induced grants.  The court observed that in U.S. v. Aerodex, Inc., 469 F.2d 1003, 1011 (5th Cir. 1972), the Fifth Circuit held that damages under the Act are limited to "the amount that was paid out by reason of the false claim," and that in U.S. ex rel. Schwedt v. Planning Research Corp., 59 F.3d 196, 200 (D.C. Cir. 1995), the D.C. Circuit held that damages amount to "only those damages that would not have come about if the defendant's misrepresentations had been true."  The court further noted that the Fifth Circuit requires a direct causal nexus between the false statement and the damage sustained by the government.  Consequently, the court determined that all of the funds received under the four contracts were directly linked to the defendants' misrepresentations.  However, no consequential damages were recoverable.  Relying on Aerodex, the court rejected the defendants' "no harm, no foul" argument that the government did not sustain any damages, since it received the benefit of its bargain with the defendants.  The court held that the government did not receive what it bargained for, since the government would not have accepted the defendants' proposal had the defendants been truthful.  The court determined that the benefit of the government's bargain was to award funds to eligible and deserving small businesses, and the defendants were not eligible to receive those funds.  Moreover, the court found that since the contracts at issue were not traditional procurement contracts, the government never received an end product from the defendants, and thus, the contracts did not result in any tangible benefit to the government.  Instead, the court held that the government had been damaged for the entire amount of the contracts, since all of the funds awarded to the defendants were diverted from other, deserving small businesses.  Therefore, in accordance with the D.C. Circuit Court's ruling in U.S. v. TDC Mgmt Corp., Inc., the district court determined that the entire value of the SBIR program was lost, since the very purpose of the program -- to make small businesses more competitive -- was frustrated.  As a result, the court held that "the proper amount of actual damages for the Four Contracts is the amount paid out on the Four Contracts -- $1,657,455.00 -- multiplied by three for a total of $4,972,365.00."

 

Civil Penalty

 

The court then turned to the civil penalty to be assessed against the defendant.  The court noted that the False Claims Act provided for a minimum penalty of 5,500 and a maximum penalty of $11,000, but observed that one of the four contracts predated an amendment of the civil penalties provision, and thus, any civil penalty under that contract was capped at $10,000.  In calculating the civil penalty, the court first considered whether a penalty should be assessed for each of the 54 vouchers the defendants submitted under the four contracts.  The court, applying the Supreme Court's rationale in U.S. v. Bornstein, 423 U.S. 303 (1976) and U.S. ex rel. Marcus v. Hess, 317 U.S. 537 (1943), concluded that civil penalties should be assessed for each of the defendants' causative acts.  The court held that the four contracts comprised the defendants' causative acts, and therefore the court assessed four civil penalties against the defendants.  The court further held that the the defendants would be assessed the maximum penalty for each forfeiture, since they engaged in a knowing and systematic fraud.  Thus, the court assessed the maximum civil penalty of $10,000 for the earliest contract, and the maximum civil penalty of $11,000 for each of the three subsequent contracts, for a total penalty of $43,000. 

 

 

 

 

 

C.     Section 3730(d)(1) Reasonable Attorneys’ Fees

 

 

 

U.S. ex rel. LeFan v. General Electric Company, 2008 WL 152091 (W.D. Ky. Jan. 15, 2008)

 

After the government intervened and settled a qui tam action, the relators filed Section 3730(d)(1) motions, seeking “reasonable” attorneys’ fees and costs against the defendant. While a Kentucky district court recognized that it was free to look to a national market in determining “reasonable fees,” particularly given the area of legal specialization, it chose to reduce the relators’ attorneys’ fees to correspond to the “going rate” for complex civil litigation in the jurisdiction. However, to compensate the firms for their delay in receiving payment during the sixteen years of litigation, the court calculated the attorneys’ fees based on their current hourly rates. Over the defendants’ objections, the court awarded the relators attorneys’ fees for the time they spent assisting the government with the government’s factual investigation. Lastly, the court awarded attorneys’ fees for the time spent preparing and successfully litigating the fee petition, especially since the allotted time was less than three percent of the hours of the main case. 

 

 

 

 

 

D.     Section 3730(d)(4) Attorneys’ Fees & Expenses for “Frivolous” Qui Tam Suits

 

 

 

U.S. ex rel. Haight v. Catholic Healthcare West, 2008 WL 607150 (D. Ariz. Feb. 29, 2008)

 

An animal rights group brought an FCA qui tam action against a medical research facility, alleging that it made false claims in connection with an NIH research grant application to fund cancer research involving the use of dogs. After an Arizona district court granted summary judgment in favor of the defendant-facility, the defendant-facility filed a 31 U.S.C. § 3730(d)(4) motion seeking attorneys’ fees and expenses from the relator. While the defendant-facility conceded that the underlying allegations were not “frivolous,” it argued that Section 3730(d)(4) still applied, for the relator’s “obvious social agenda” demonstrated that it was “brought primarily for purposes of harassment.” In denying the motion, the district court declared that, given the potential “sizeable award,” it could not conclude that the suit was primarily brought for purposes of harassment, as required to award § 3730(d)(4) attorneys’ fees and expenses.

 

An animal rights group brought an FCA qui tam action against a medical research facility, alleging that it made false claims in connection with an NIH research grant application to fund cancer research involving the use of dogs. While the district court ultimately dismissed the relator’s action, it concluded that the claims were not so lacking in legal merit as to be deemed frivolous. Nevertheless, the defendants subsequently filed a motion seeking attorneys’ fees and expenses pursuant to 31 U.S.C. § 3730(d)(4), arguing that even though the claims were not “frivolous,” Section 3730(d)(4) still applied, for the claims were “brought primarily for purposes of harassment.” Specifically, the defendants claimed that the relator used this litigation to advance its social agenda of stopping the use of animals in medical research.

 

Suit Was Not Brought Primarily For Purposes Of Harassment

 

Section 3730(d)(4) provides for attorneys fees to a prevailing defendant when a plaintiff's claims are “clearly frivolous” or “brought primarily for purposes of harassment.” In parsing the language of the Act, the court noted that if evidence of an improper motive were the only consideration, the inquiry would end. However, § 3730(d)(4) provides that not only must evidence exist that plaintiffs were motivated by an improper purpose, but also that their claims were brought “primarily” for that purpose. Having previously concluded that the relator’s claims were not frivolous, the court was unable to conclude that the promotion of relator’s social agenda was “paramount over asserting their non-frivolous claims that, if successful, could have earned them a sizable award.” In turn, because there was no showing that the claims were brought primarily for purposes of harassment, the court denied the defendants’ § 3730(d)(4) motion for attorneys’ fees and non-taxable costs.

 

Prevailing Party Awarded FRCP 54(d)(1) Costs

 

The court then took up the issue of whether the defendants were allowed costs under FRCP 54(d)(1). Rule 54(d)(1) provides that costs other than attorneys’ fees “should be allowed to the prevailing party.” Citing an earlier Ninth Circuit decision, the court laid out the controlling case law: “The unsuccessful litigant can overcome this presumption [in favor of the award of costs under Rule 54(d)] only by pointing to some impropriety on the part of the prevailing party that would justify a denial of costs.... A district court therefore must award costs unless the prevailing party is guilty of some fault, misconduct, or default worthy of punishment.” U.S. ex rel. Lindenthal v. General Dynamics Corp., 61 F.3d 1402, 1414 (9th Cir.1995) (applying Rule 54(d) in a False Claims Act case) (citation omitted).

 

While the relator did not allege any impropriety or misconduct on the part of the defendants, the relator claimed that a permissive award of costs would chill the exercise of rights by qui tam litigants both in this case and other FCA cases. However, the court countered that such a blanket exclusion of costs in FCA cases was rejected in Lindenthal. Id. at 1413-14.

 

With no evidence of “some impropriety on the part of the” defendants, the court allowed costs in the amount taxed by the clerk of the court.

 

 

 

 

 

 

U.S. ex rel. Chabot v. Westgate Homes, Inc., 2008 WL 360785 (M.D. Fla. Feb. 8, 2008)

 

After a relator served his unsealed qui tam complaint on the defendant, the defendant filed an answer in which it denied the relator’s claims and asserted a counterclaim for attorneys’ fees and expenses under 31 U.S.C. § 3730(d)(4). The relator, in moving to dismiss the counterclaim, argued that Section 3730(d)(4) does not create an independent cause of action. While a Florida district court ruled that, as a matter of procedural technicality, § 3730(d)(4) could not be raised as a counterclaim, the court did allow the “substance” of the demand, for it placed the relator on notice that such an award would be sought if the defendant prevailed.

 

Gregory Chabot brought an FCA qui tam action against Westgate Homes, Inc. When the government declined to intervene in the suit, Chabot served the complaint on the defendant. Subsequently, Westgate filed an answer, which included a counterclaim seeking attorneys’ fees and expenses under 31 U.S.C. 3730(d)(4). Chabot filed a motion to dismiss the counterclaim as procedurally improper.

 

Chabot argued that Westgate’s Counterclaim was improper because Section 3730(d)(4) does not create an independent cause of action. Instead, Chabot maintained, “a claim for fees and costs must be made by motion only if [Westgate] prevails and can establish that the claims were objectively frivolous, vexatious or brought for the purpose of harassment.”

 

Section 3730(d)(4) Simply Needs To Be Raised By Motion, Not As A Cause of Action

 

As an initial matter, the court noted that it is well established that unless otherwise specified by statute, a request for an award for attorneys’ fees is “simply a demand for a particular remedy” rather than an independent cause of action. E .g., Valcon II, Inc. v. United States, 26 Cl.Ct. 393, 398 (Cl.Ct. 1992). Moreover, the Eleventh Circuit has explained that a party’s failure to plead a demand for attorneys’ fees will not usually bar that party from later seeking attorneys’ fees. Capital Asset Research Corp. v. Finnegan, 216 F.3d 1268, 1270-71 (11th Cir. 2000) (citing Engel v. Teleprompter Corp., 732 F.2d 1238, (5th Cir. 1984)).

 

Thus, as a matter of procedural technicality, the court agreed that Westgate erred in labeling its demand for attorneys’ fees as a counterclaim. However, the court ruled that the substance of the demand was appropriate, for it puts Chabot on notice that such an award will be sought if it prevails and the statutory requirements are satisfied. Therefore, the court did not strike the demand itself.

 

 

 

 

 

 

U.S. ex rel. Montgomery v. St. Edward Mercy Medical Center, 2008 WL 110858 (E.D. Ark. Jan. 8, 2008)

 

After an FCA defendant was successful in using the recent U.S. Supreme Court Rockwell decision to dismiss a qui tam suit, it filed a motion with an Arkansas district court seeking attorneys’ fees and expenses pursuant to 31 U.S.C. § 3730(d)(4). In denying the defendant’s motion, the court ruled that it could not deem the suit “frivolous” under § 3730(d)(4), especially since the deciding Rockwell decision was not established law when the originally filed his qui tam suit.

 

 

 

 

II.      JURISDICTIONAL ISSUES

 

 

A.     Section 3730(e)(4) Public Disclosure Bar and Original Source Exception

 

 

 

U.S. ex rel. Duxbury v. Ortho Biotech Products, L.P., 2008 WL 244304 (D. Mass. Jan. 25, 2008)

 

After the government declined to intervene in a former sales representative’s qui tam action against a pharmaceutical manufacturer, a Massachusetts district court granted the relator’s motion to amend his complaint and to add a co-relator pursuant to FRCP 15(a). However, then, the defendant-manufacturer moved to dismiss the amended complaint, arguing, inter alia, that the FCA public disclosure bar, 31 U.S.C. § 3730(e)(4), applied and that the complaint failed to satisfy the particularity requirements of FRCP 9(b). The court agreed that the FCA public disclosure bar applied and that the second relator did not qualify for the bar’s § 3730(e)(4)(B) original source exception, for he had failed to  “voluntarily provide[] information to the government before filing [his] action.” Moreover, the court stressed that even if the second relator qualified for the exception, the Section 3730(b)(5) first-to-file bar would have barred him, for the first relator’s complaint was still “pending” at the time the second relator was added as a co-plaintiff. Turning its attention to the first relator, the court determined that he qualified for the bar’s original source exception, but only for the time that he was employed by the defendant-manufacturer. However, the court noted that in the time period between the filing of the original complaint and the filing of the amended complaint, a qui tam action was filed--and dismissed--in another court that raised the same allegations that the first relator now wished to elaborate on in his amended complaint. The court ruled that “bare bones allegations” in the original complaint was not sufficient to qualify him as the first person to file on these particular allegations. Then, without addressing the question of whether the action in the other suit was still actually “pending,” the court dismissed the amended complaint under the § 3730(b)(5) first-to-file bar. Lastly, the court ruled that the complaint was also dismissed under Rule 9(b), for while the relator detailed the underlying fraudulent marketing scheme, he failed to tie the scheme to a false claim that was actually submitted to the government.

 

From 1992 to 1998, Mark Duxbury climbed the corporate ladder at Ortho Biotech Products, L.P., ultimately becoming a regional key account specialist for the oncology sales force. In this position, he uncovered a number of illegal marketing practices. When the company refused to change its practices, he filed a FCA qui tam suit against the company in November of 2003.     

 

Two years later, in July 2005, the United States declined to intervene in the suit. Subsequently, the court granted Duxbury’s FRCP 15(a) motion to amend his complaint and to add fellow Ortho employee Dean McClellan as a co-relator. At that time, the court noted that McClellan did not bring any new legal claims against Ortho, but rather added additional supporting facts to the legal claims previously made by Duxbury.

 

The relators alleged three separate FCA violations in their amended complaint. First, they alleged that beginning in 1992, Ortho undertook a scheme to give kickbacks to providers and hospitals to induce them to prescribe Procrit. The kickbacks allegedly included free samples, off-invoice discounts, rebates, consulting fees, educational grants, payments to participate in studies or trials and advisory board honoraria. The relators alleged that the kickbacks caused providers and hospitals to submit false claims for payment to Medicare. They claim that the time period of the false claims is from “December 1992 to the present.”

 

Third, the relators alleged that Ortho promoted off-label dosing of Procrit in violation of the Food, Drug and Cosmetic Act and used “sham drug trials” to falsify eligibility for Medicare reimbursement for off-label uses of the drug. The relators claimed that the time period for this claim was from January 1998 to the present.

 

Ortho moved to dismiss the amended complaint in its entirety on the grounds that the court lacked jurisdiction under the public disclosure bar, that certain claims were barred by the “first-to-file” rule, and that the relators had failed satisfy Rule 9(b).

 

Public Disclosure Bar Applied

 

The court first turned it attention to relators’ kickback allegations, which Ortho maintained was blocked by the FCA public disclosure bar. Ortho asserted that the essential elements supporting this claim were publicly disclosed in prior civil litigation and various government and media reports prior to Duxbury filing his initial complaint in November 2003. The prior litigation highlighted by Ortho was the multi-district AWP litigation taking place in the District of Massachusetts, In re Pharmaceutical Industry Average Wholesale Price Litigation, MDL No. 1456, Civ. No. 01-12257-PBS (“AWP MDL”).

 

Relators argued that the AWP MDL did not publicly disclose Ortho’s alleged fraud because (1) “it only revealed the component of Ortho’s scheme that involved consumers, insurers and third party payers but not the manipulation of the Medicare reimbursement system,” and (2) “it did not contain elements of the scheme of having Ortho’s sales force intentionally cause the submission of false claims to the Government.”

 

Without much discussion, the court ruled that a § 3730(e)(4) “public disclosure” occurred, for the allegations in the AWP MDL predated the relators’ complaint and the allegations were substantially the same as those detailed in the relators complaint. This led the court to conclude that it was “inescapable that Relators’ claims [were] based upon the public disclosures.”

 

Qualified for Original Source Exception for Claims Submitted During His Employment

 

However, the court determined that Duxbury qualified for the public disclosure bar’s original source exception, 31 U.S.C. § 3730(e)(4)(B), for his knowledge of the alleged fraud was both independent and direct. However, the court ruled that his “direct knowledge” of Ortho’s activities only extended to the time he was employed by the company. Thus, he only qualified as an original source with regard to allegations concerning the 1992-1998 time period.

 

Co-Relator Did Not Qualify for Original Source Exception

 

McClellan, on the other hand, did not qualify for the original source exception, for he had not “voluntarily provided the information to the Government before filing an action,” as mandated under § 3730(e)(4)(B). Here, because the court found that McClellan was not asserting any new claims, but was merely adding “supporting facts to the legal claims previously made” by Duxbury, the court ruled that McClellan needed to show that he provided the information to the government prior to Duxbury filing suit in November 2003.

 

First-to-File Bar Would Have Also Prevented Co-Relator’s Suit

 

Moreover, even if McClellan qualified for the original source exception, the court stressed that he would have been tripped up by the Act’s “first-to-file” bar, 31 U.S.C. § 3730(b)(5). The court, declaring the first-to-file bar to be “exception-free,” ruled that the bar “cannot be circumvented simply by amending the complaint to add McClellan as a relator when his claims would have been barred had they been brought on their own.”

 

Relators’ Initial Allegations Were Not Sufficient To Qualify As Being “First-Filed”

 

The court then turned its attention to the relators’ off-label marketing claims. The court observed that one month after Duxbury filed his original qui tam complaint, a separate relator filed a qui tam complaint in the District of Colorado that also alleged a scheme by Ortho to off-label market Procrit. (Notably, the District of Colorado qui tam suit was dismissed prior to the relators filing their amended complaint.)

 

While Ortho conceded that the relators’ amended complaint included off-label marketing allegations, Ortho maintained that these allegations were not in the original complaint, so they were barred under the first-to-file bar. (Of particular note, neither party raised the issue of whether the District of Colorado suit was “pending” at the time the relators filed their amended complaint. Because neither party raised the issue, the court also took a pass on the question.)

 

While seeming to credit Duxbury for including the off-label allegations in his original complaint, the court disregarded their inclusion as being “bare bones allegations” that were not sufficient “placeholder[s] for the widespread off-label marketing scheme that relators now wish to allege.” Likewise, the court ruled that these allegations were not sufficient to trigger the first-to-file rule when it came to the later-filed District of Colorado suit. However, without diving into the sufficiency of the District of Colorado complaint, the court ruled that this later-filed suit blocked the off-label allegations detailed in the relators’ amended complaint. In turn, the court dismissed the relators’ off-label allegations under the Act’s first-to-file bar.    

 

Allegations Failed To Satisfy Rule 9(b)

 

Returning its attention to Duxbury’s 1992-1998 kickback allegations, the court then assessed whether these allegations satisfied the Rule 9(b) pleading requirements. Citing the First Circuit’s Karvelas decision, the court stressed that “it is not enough to allege details of the scheme if there are not also particularized allegations regarding the false claims that were actually submitted to the federal government.” 

 

Here, while Duxbury did not identify an individual piece of paper that was submitted to the government, he identified individual providers, approximate amounts of free samples, discounts, “off-invoice” rebates, and educational grants involved in the scheme. Perhaps overlooking or misreading U.S. ex rel. Rost v. Pfizer, Inc., 507 F.3d 720 (1st Cir. 2007), the court ruled that this was not sufficient to satisfy Rule 9(b).

 

Accordingly, although court concluded that it had subject matter jurisdiction to hear Duxbury’s claims of alleged kickbacks which occurred during his employment at Ortho, the court dismissed the claims with prejudice for failing to satisfy Rule 9(b). 

 

 

 

 

 

 

 

III.           FALSE CLAIMS ACT RETALIATION CLAIMS

 

 

 

 

U.S. ex rel. Erickson v. Unitah Special Svcs. Dist., 2008 WL 634979 (10th Cir. Mar. 6, 2008)

 

Relator brought a section 3730(h) anti-retaliation claim against her former employer. In affirming a Utah district court’s dismissal of the suit, the Tenth Circuit agreed that the relator had failed to demonstrate that she was terminated “because of” FCA-protected conduct. Specifically, the court highlighted an independent audit report that detailed numerous non-retaliatory bases for terminating the plaintiff.

 

Pro se relator Kathryn Erickson filed a False Claims Act suit against her former employer, alleging that she was suspended and later terminated from her general manager job because she exposed her company’s alleged misuse of federal funds.  In response, the defendant alleged that Erickson was fired in response to a report prepared by an independent auditor that raised concerns about various payments the company had made, which did not conform to the company’s internal policies.  The defendant moved for summary judgment, which the district court granted.  The relator appealed.

 

The Tenth Circuit affirmed the district court’s ruling.  The court relied on the district court’s finding that the independent audit report provided multiple bases for terminating the relator and refused to consider Erickson’s appellate arguments – arguments that were not raised with the district court – that the defendant failed to follow its procedures when it suspended and then fired her, that the defendant could not have relied on the audit report as a basis for firing her, since that report had not been completed at the time of her termination, and that the defendant should have been required to defend and indemnify her with respect to her subsequent criminal indictment for obstruction of justice for knowingly falsifying documents. 

 

 

 

 

 

 

Hoyte v. American National Red Cross, 2008 WL 564649 (D.C. Cir. Mar. 4, 2008)

 

A panel of the D.C. Circuit, in affirming the D.C. District Court’s dismissal of an action alleging a reverse False Claims Act violation,  agreed that it was obliged to defer to the federal government’s decision to dismiss the reverse false claim count. However, only a majority of the panel held that the dismissal of the underlying FCA suit necessitated the dismissal of the relator’s anti-retaliation suit.

 

Michelle Hoyte was formerly employed as the Director of Quality Audits for the American Red Cross. Hoyte alleged that in February 2004, while serving in that capacity, she discovered that the American Red Cross had mishandled over 600 units of blood at one of its facilities, and that officials and staff of the American Red Cross were aware of the mishandled blood but did nothing about it.  Prior to this occurring, in April 2003, the D.C. District Court issued a consent decree, which incorporated an agreement between the American Red Cross and the United States, which outlined certain blood handling and reporting requirements that the American Red Cross had agreed to follow.  The consent decree further provided that the Food and Drug Administration could asses various penalties against the American Red Cross – up to specified maximums -- should it violate the consent decree.

 

Hoyte alleged that she urged the staff at the American Red Cross to report the mishandled blood to the Food and Drug Administration, as the consent decree required, but they did nothing.  She alleged that she scheduled a meeting with the American Red Cross’s Senior Vice President for Quality Assurance and Regulatory Affairs, but was fired by her supervisor by telephone on the day before the meeting was to take place.  She then filed a qui tam action, alleging both a reverse false claim count, under section 3729(a)(7), as well as a retaliation count, under section 3729(h).  The American Red Cross moved to dismiss both counts and, subsequently, the federal government moved to dismiss the reverse false claim count.  The D.C. District Court first granted the government’s motion to dismiss the first count, and later granted the American Red Cross’s motion to dismiss the second count.  Hoyte appealed both orders.

 

Reverse False Claims Act Claim Was Properly Dismissed

The D.C. Circuit affirmed the lower court’s rulings, and held that, the district court properly dismissed the reverse false claims count, since the federal government moved to dismiss that count, and since, absent a showing of fraud on the court – and there was no evidence of fraud on the court in this case – “the Government has what amount to ‘an unfettered right to dismiss’ a qui tam action.”  The court rejected the relator’s proposal that the court recognize an exception for federal government motions to dismiss that are “clearly contrary to manifest public interest.”

 

Retaliation Claim Was Properly Dismissed

With respect to the second count, for retaliation, the D.C. Circuit, relying on its rationale outlined in U.S. ex rel. Yesudian v. Howard Univ., 153 F.3d 731 (D.C. Cir. 1998),  again affirmed the lower court’s ruling concluding that the matters Hoyte was investigating could not have reasonably led to a viable False Claims Act case, since she never alleged that the American Red Cross was under any obligation to transmit any money to the federal government, and thus, could not have violated section 3729(a)(7) of the False Claims Act.  The court noted that the consent decree did not impose any such obligation on the American Red Cross.  The court determined that Hoyte was simply investigating “mere regulatory noncompliance,” not false or fraudulent claims.

 

The Dissent

Circuit Judge Tatel wrote a separate opinion, concurring in part and dissenting in part.  This opinion notes that, although the reverse False Claims Act claim was properly dismissed, Hoyte’s retaliation claim should have not been dismissed, since, pursuant to Yesudian, a relator only needs to show that “they reasonably believed their employer violated the FCA – a standard Hoyte plainly satisfies.”

 

 

 

 

 

 

 

Martin v. ARC of D.C., 2008 WL 821044 (D.D.C. Mar. 28, 2008)

Plaintiff filed a False Claims Act suit against her former employer, which received federal funds from the Department of Health and Human Services, as well as funds from the District of Columbia.  The complaint alleged, inter alia, that the employer violated the False Claims Act by firing her when she complained about the employer’s alleged negligence and fraud in servicing its clients, who were mentally retarded and developmentally disabled people.  The employer moved to dismiss, arguing that the complaint failed to satisfy Rule 12(b)(6).  In granting the motion, the court noted the controlling case law, which mandates that “the relator must be investigating matters that reasonably could lead to a viable FCA case.” Here, because the court determined that she did not have a “viable FCA claim,” and was instead merely “investigating the defendant’s failure to comply with its funding requirements,” the court ruled that she could not bring an actionable claim under the Act’s anti-retaliation provision.

Plaintiff Lowry Martin  filed an action against her former employer, the Arc of the District of Columbia, alleging that the defendant violated both the False Claims Act and the District of Columbia Whistleblower Protection Act, when it allegedly received federal funds from the Department of Health and Human Services through the Mental Retardation and Development disabilities Administration, but neglected its duties to assist its mentally retarded and developmentally disabled clients find jobs by failing to fulfill its obligations to hire qualified job coaches for its clients – the defendant was required to hire job coaches with at least one year of experience, which, the plaintiff alleged, they failed to do.  She alleged that the defendant must have submitted false documents to the federal government, since the defendant could not obtain annual funding from the federal government without falsely certifying that it had complied with its job coach hiring requirements.  The plaintiff further alleged that when she filed a grievance with the defendant regarding this alleged conduct, she was ignored and then terminated.  As a result, she commenced her lawsuit, alleging, among other things, a substantive violation of the False Claims Act, a retaliation claim under the False Claims Act and a claim under the D.C. Whistleblower Protection Act.  The defendant moved to dismiss the action, arguing that the complaint did not state a claim under Rule 12(b)(6). The district court dismissed the False Claims Act and Whistleblower Protection Act claims.

Complaint Did Not State a Claim for a Substantive Violation of the False Claims Act

The court first noted that “[n]owhere in plaintiff’s complaint does she allege that a fraudulent claim was submitted to the government for payment, nor does she allege who submitted such a claim, nor the time frame for when the fraudulent submissions were made.”  The court observed that the plaintiff requested an opportunity to use discovery as a means to find evidence to support her allegations that a false statement must have been made to the federal government, since the federal government gave the defendant money even though the defendant had not complied with the federal government’s funding requirements.  The court determined that the plaintiff had not pled fraud with particularity, “because the complaint fails to identify who, if anyone, made a false representation to the government and fails to provide any of the purported details such as the time, place, and contents of the alleged false representation.”  Thus, the substantive False Claims Act claim was dismissed.

Complaint Did Not State A Claim For Retaliation Under the False Claims Act

The court next dismissed the plaintiff’s False Claims Act retaliation claim.  Citing its 4-week old decision in Hoyte v. American National Red Cross, 2008 WL 564649 (D.C. Cir. Mar. 4, 2008), the court noted that in order to bring a retaliation claim under the False Claims Act, “the relator must be investigating matters that reasonably could lead to a viable FCA case.  An employee’s investigation of nothing more than his employer’s non-compliance with federal or state regulations does not state a claim under the FCA.”  Here, the court opined, the relator failed to produce any false certifications upon which the defendant’s funding was conditioned.  Moreover, the court found that the plaintiff did not allege any facts demonstrating that she was investigating a viable FCA claim, merely that she was investigating the defendant’s failure to comply with its funding requirements.  Therefore, the court held that her retaliation claim should be dismissed.

 

 

 

 

 

 

Haka v. Lincoln County, 2008 WL 314046 (W.D. Wis. Feb. 4, 2008)

 

A recently terminated county child support administrator brought a 31 U.S.C. § 3730(h) anti-retaliation suit against the county and the county board of supervisors. In a motion for summary judgment, the defendant-board of supervisors argued that the plaintiff had failed to state an actionable § 3730(h) claim, for he did not show that a majority of the county board acted with a retaliatory motive when it voted to eliminate the plaintiff’s position. In denying the defendant-board’s motion, the court ruled that once the plaintiff established the unlawful motive of an individual with significant influence over the board, it became the defendant-board’s burden to show that the board would have made the same decision even if the member did not have a retaliatory motive.