Graham County Soil and Water Conservation District v. United States (2009)
- Docket
- 08-304
- Decided
- 2009-01-01
Summary
Question: Does an audit performed by a state or its political subdivisions constitute an administrative report within the meaning of the public disclosure jurisdictional bar of the False Claims Act? Conclusion: Yes. The Supreme Court reversed the Fourth Circuit, holding that the reference to "administrative" reports, audits, and investigations within the FCA encompasses disclosures made in state and local sources as well as federal sources – like at issue in this case. With Justice John Paul Stevens writing for the majority, the Court reasoned that the FCA's plain language did not limit "administrative" to federal sources, nor did it preclude the inclusion of state sources. Moreover, the Court looked at the legislative history of the FCA and found it inconclusive. Justice Antonin G. Scalia wrote separately, concurring in part and concurring in the judgment. He emphasized that the legislative history of a statute is not relevant in analyzing what a statute means. Justice Sonia Sotamayor joined by Justice Stephen G. Breyer also wrote separately, dissenting. She disagreed with the majority opinion in that it did not give sufficient weight to contextual and historical evidence of Congress' purpose in enacting the FCA. Under her analysis, she would hold that "administrative" refers only to federal sources.