Little v. Shell Exploration & Production Co.

LESLIE H. SOUTHWICK, Circuit Judge:

This case presents an issue of first impression for our court. Is a federal employee, even one whose job it is to investigate fraud, a “person” under the False Claims Act such that he may maintain a qui tam action? We disagree with the district court and conclude that there is no basis to except such an employee from personhood. A second question is whether the Act’s “public disclosure bar” is an impediment to this suit. The district court determined that this bar applied but used an overly broad conception of the bar. We REVERSE and REMAND for further…