Rockwell International Corp. v. United States
Encyclopedia
Rockwell International Corp. v. United States, No. 05-1272, 549 U.S. 457 (2007), was a case in which the Supreme Court of the United States
that examined the "original source" exception to the "public-disclosure" bar of the False Claims Act
. The Court held that (1) the original source requirement of the FCA provision setting for the original-source exception to the public-disclosure bar on federal-court jurisdiction is jurisdictional; (2) the statutory phrase "information on which the allegations are based" refers to the relator's allegations and not the publicly disclosed allegations; the terms "allegations" is not limited to the allegations in the original complaint, but includes, at a minimum, the allegations in the original complaint as amended; (3) relator's knowledge with respect to the pondcrete fell short of the direct and independent knowledge of the information on which the allegations are based required for him to qualify as an original source; and (4) the government's intervention did not provide an independent basis of jurisdiction with respect to the relator.
relator James Stone brought an action against government contractor, Rockwell International Corporation, alleging that it violated the False Claims Act
while operating a nuclear weapons plant. In the course of defending against the relator's action, Rockwell filed a motion to dismiss for lack of subject-matter jurisdiction
based on the relator's alleged failure to qualify as an original source under the FCA. Rockwell's motion was denied by the district court.
The U.S. Government intervened, pursuant to the intervention provisions of the FCA, and together with the relator, filed a joint amended complaint alleging, among other things, that Rockwell committed environmental violations by storing leaky blocks of pondcrete--a form of processed toxic waste. Following a jury trial, the United States District Court for the District of Colorado entered judgment in favor of the United States and relator Stone. As a result, the district court awarded statutorily-provided treble damages to the plaintiffs.
Rockwell appealed the judgment, and the Tenth Circuit affirmed in relevant part, but remanded for a determination of whether the relator had satisfied a statutory requirement of disclosing information underlying his claims to the government prior to bringing suit. On remand, the district court found that the relator had not made an adequate disclosure, and appeal was taken. The Tenth Circuit Court of Appeals held that the relator was an original source.
granted certiorari
on the limited original source issue.
Justice Breyer took no part in consideration or decision of this case.
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
that examined the "original source" exception to the "public-disclosure" bar of the False Claims Act
False Claims Act
The False Claims Act is an American federal law that imposes liability on persons and companies who defraud governmental programs. The law includes a "qui tam" provision that allows people who are not affiliated with the government to file actions on behalf of the government...
. The Court held that (1) the original source requirement of the FCA provision setting for the original-source exception to the public-disclosure bar on federal-court jurisdiction is jurisdictional; (2) the statutory phrase "information on which the allegations are based" refers to the relator's allegations and not the publicly disclosed allegations; the terms "allegations" is not limited to the allegations in the original complaint, but includes, at a minimum, the allegations in the original complaint as amended; (3) relator's knowledge with respect to the pondcrete fell short of the direct and independent knowledge of the information on which the allegations are based required for him to qualify as an original source; and (4) the government's intervention did not provide an independent basis of jurisdiction with respect to the relator.
Prior history
Qui tamQui tam
In common law, a writ of qui tam is a writ whereby a private individual who assists a prosecution can receive all or part of any penalty imposed...
relator James Stone brought an action against government contractor, Rockwell International Corporation, alleging that it violated the False Claims Act
False Claims Act
The False Claims Act is an American federal law that imposes liability on persons and companies who defraud governmental programs. The law includes a "qui tam" provision that allows people who are not affiliated with the government to file actions on behalf of the government...
while operating a nuclear weapons plant. In the course of defending against the relator's action, Rockwell filed a motion to dismiss for lack of subject-matter jurisdiction
Subject-matter jurisdiction
Subject-matter jurisdiction is the authority of a court to hear cases of a particular type or cases relating to a specific subject matter. For instance, bankruptcy court only has the authority to hear bankruptcy cases....
based on the relator's alleged failure to qualify as an original source under the FCA. Rockwell's motion was denied by the district court.
The U.S. Government intervened, pursuant to the intervention provisions of the FCA, and together with the relator, filed a joint amended complaint alleging, among other things, that Rockwell committed environmental violations by storing leaky blocks of pondcrete--a form of processed toxic waste. Following a jury trial, the United States District Court for the District of Colorado entered judgment in favor of the United States and relator Stone. As a result, the district court awarded statutorily-provided treble damages to the plaintiffs.
Rockwell appealed the judgment, and the Tenth Circuit affirmed in relevant part, but remanded for a determination of whether the relator had satisfied a statutory requirement of disclosing information underlying his claims to the government prior to bringing suit. On remand, the district court found that the relator had not made an adequate disclosure, and appeal was taken. The Tenth Circuit Court of Appeals held that the relator was an original source.
Case
The United States Supreme CourtSupreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
granted certiorari
Certiorari
Certiorari is a type of writ seeking judicial review, recognized in U.S., Roman, English, Philippine, and other law. Certiorari is the present passive infinitive of the Latin certiorare...
on the limited original source issue.
Justice Breyer took no part in consideration or decision of this case.