Vermont Agency of Natural Resources v. United States ex rel. Stevens
| Vermont Agency of Natural Resources v. United States ex rel. Stevens | |
|---|---|
 | |
| Argued November 29, 1999 Decided May 22, 2000 | |
| Full case name | Vermont Agency of Natural Resources v. United States ex rel. Stevens |
| Docket no. | 98-1828 |
| Citations | 529 U.S. 765 (more) 120 S. Ct. 1858 |
| Argument | Oral argument |
| Opinion announcement | Opinion announcement |
| Holding | |
| A private individual may not bring suit in federal Court on behalf of the United States against a State or state agency under the False Claims Act. | |
| Court membership | |
| |
| Case opinions | |
| Majority | Scalia, joined by Rehnquist, O'Connor, Kennedy, Thomas, Breyer |
| Concurrence | Breyer |
| Concurrence | Ginsburg, joined by Breyer |
| Dissent | Stevens, joined by Souter |
| Laws applied | |
| False Claims Act of 1863 | |
Vermont Agency of Natural Resources v. United States ex rel. Stevens, 529 U.S. 765 (2000), is a United States Supreme Court case in which the Court held a private individual may not bring suit in a federal court on behalf of the United States against a State (or state agency) under the False Claims Act.[1]
Background
[edit]The FCA includes a qui tam provision that a private person (the relator) may file actions on behalf of the U.S. government against any "person" who presents to the government a false or fraudulent claim for payment. The relator stands to receive a share of any recovered damages.[2]
Relator Stevens, a former employee of the Vermont Agency of Natural Resources, brought a qui tam civil action against the agency, alleging that the state agency had submitted false claims to the U.S. Environmental Protection Agency (EPA) in connection with federal grant programs the EPA administered.[3]
At the U.S. District Court for the District of Vermont, the Vermont state agency moved to dismiss, arguing that a State or state agency is not a "person" subject to FCA liability and that a qui tam action in federal court against a State is barred by the Eleventh Amendment of the U.S. Constitution.
The district court denied the motion, and the Vermont state agency appealed. The United States intervened in the appeal in support of relator Stevens. The U.S. Court of Appeals for the Second Circuit affirmed.
The Supreme Court granted certiorari to Vermont and heard the oral argument on November 29, 1999.
Opinion of the Court
[edit]The Supreme Court reversed the judgment of the Court of Appeals.[1]
In a decision delivered by Justice Scalia, the Court held that the FCA does not subject a State (or state agency) to liability in a federal court suit by a private individual on behalf of the United States because such a State or agency is not a "person" subject to qui tam liability under . The Court also held that Stevens had standing under the FCA as the Government's damages claim is partially assigned to him, citing Steel Co. v. Citizens for Better Environment, 523 U.S. 83 (1998).[1][4]
Justice Ginsburg, with whom Justice Breyer joined, concurred in the judgment. Justice Stevens, with whom Justice Souter joined, dissented.[1]
See also
[edit]- False Claims Act of 1863
- Qui tam
- List of United States Supreme Court cases
- Lists of United States Supreme Court cases by volume
- List of United States Supreme Court cases by the Rehnquist Court
References
[edit]- ^ a b c d Vermont Agency of Natural Resources v. United States ex rel. Stevens, 529 U.S. 765 (2000).
- ^ "Civil Division | The False Claims Act". www.justice.gov. 2019-06-17. Retrieved 2025-02-02.
- ^ "Vermont Agency of Natural Resources v. United States ex rel. Stevens". The Environmental Law Reporter by the Environmental Law Institute. 30: 20405.
- ^ Sturycz, Nathan (January 16, 2010). "The King and I?: An Examination of the Interest Qui Tam Relators Represent and the Implications for Future False Claims Act Litigation". St. Louis University Public Law Review. 28: 459 – via Elsevier.
External links
[edit]- Text of Vermont Agency of Natural Resources v. United States ex rel. Stevens, 529 U.S. 765 (2000) is available from: Google Scholar Justia Library of Congress
- Qui Tam: The False Claims Act and Related Federal Statutes by Congressional Research Service, April 26, 2021