False Claims Act
State Farm Fire & Casualty Co. v. United States15-513
What standard governs the decision whether to dismiss a relator’s claim for violation of the False Claims Act’s seal requirement, 31 U.S.C. § 3730(b)(2)?
DECISIONDecided December 6, 2016 HOLDING
A seal violation does not mandate dismissal of a relator’s complaint. The District Court did not abuse its discretion by denying petitioner’s motion to dismiss. The question whether dismissal is appropriate should be left to the sound discretion of the district court. On this record, where petitioner requested no sanction other than dismissal, the question whether a lesser sanction—such as monetary penalties—is warranted is not preserved.
KENNEDY, J., delivered the opinion for a unanimous Court.
ORAL ARGUMENTArgued November 1, 2016
CERTIORARI STAGEGranted May 31, 2016
United States Court of Appeals for the Fifth Circuit
Decided July 13, 2015