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Schindler Elevator Corp. v. US ex rel. Kirk

Docket No.10-188
Op. Below2d Circuit
ArgumentMar 1, 2011

Holding

A federal agency's written response to a FOIA request for records is a "report"? within the meaning of the disclosure bar of the False Claims Act. (Kagan, J., recused).

Plain English Holding

A private plaintiff may not sue a government contractor under the False Claims Act (which provides a bounty for private litigants who prove fraud against the government by government contractors) based on fraud that had already been disclosed by the government in response to a request under the Freedom of Information Act, which generally requires the government to disclose documents in its possession in response to an individual’s request.

Judgment

Reversed, 5-3, in an opinion by Clarence Thomas on May 16, 2011. Justice Ginsburg wrote a dissenting opinion, which was joined by Justices Breyer and Sotomayor.(Kagan, J., recused).

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