Graham County Soil & Water Conservation Dist. v. United States ex rel. Wilson, 545 U.S. 409 (2005)
Primary Holding
The 6-year statute of limitations in the False Claims Act does not govern civil actions for retaliation under §3730(h); instead, the most closely analogous state limitations period applies.
In the case of Graham County Soil & Water Conservation District v. United States, the Supreme Court decided that the time limit for filing a retaliation claim under the False Claims Act (FCA) isn't the usual 6 years but instead depends on the relevant state law. This is important because it gives employees who face retaliation for reporting fraud more time to seek justice. This ruling helps protect consumers by ensuring that whistleblowers—those who report wrongdoing—can stand up against their employers without being rushed by a strict deadline. If someone feels they’ve been punished for reporting fraud, they should know they might have more time to take action based on their state’s laws.
AI-generated plain-language summary to help you understand this case
In the case of Graham County Soil & Water Conservation District v. United States ex rel. Wilson, the underlying dispute arose when Karen T. Wilson, a former employee of the Graham County Soil and Water Conservation District, filed a qui tam action under the False Claims Act (FCA) in January 2001. Wilson alleged that the petitioners, which included local government entities and officials, had submitted false claims for federal funds. Additionally, she claimed that she faced retaliation from her employer for her involvement in the FCA investigation and for reporting these fraudulent activities. The procedural history of the case began with Wilson's filing of the FCA action, which prompted the petitioners to challenge the applicability of the statute of limitations for her retaliation claim. The key legal question was whether the 6-year statute of limitations outlined in the FCA applied to retaliation claims under §3730(h). The case ultimately reached the Supreme Court on a writ of certiorari after being decided by the United States Court of Appeals for the Fourth Circuit, which ruled on the limitations period applicable to Wilson's claims. Relevant background context includes the 1986 amendments to the FCA, which introduced provisions for private individuals to bring actions against employers for retaliation related to FCA investigations. These amendments aimed to strengthen protections for whistleblowers and clarify the enforcement mechanisms available under the FCA. The case highlights the complexities surrounding the interpretation of the statute of limitations in the context of retaliation claims, as well as the broader implications for the enforcement of the FCA.
Whether the 6-year statute of limitations in the False Claims Act governs civil actions for retaliation under §3730(h).
The judgment is reversed.
- Court
- Supreme Court
- Decision Date
- April 20, 2005
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Thomas
- Damages Awarded
- N/A
- Data Quality
- high
United States v. Olson, 546 U.S. 43 (2005)
Mixed OutcomeThe Federal Tort Claims Act (FTCA) waives sovereign immunity only in circumstances where the United States would be liable as a "private person" under local law, not based on the liability of state or municipal entities.
Dodd v. United States, 545 U.S. 353 (2005)
Consumer LostThe limitation period for filing a motion under 28 U.S.C. §2255 begins to run on the date the Supreme Court initially recognizes the right asserted, rather than the date the right is made retroactively applicable.
Johnson v. United States, 544 U.S. 295 (2005)
Consumer LostThe period for the 1-year statute of limitations under 28 U.S.C. §2255 begins when a petitioner receives notice of the order vacating a prior conviction used to enhance their federal sentence, provided that the petitioner has pursued the vacatur with due diligence in state court.
Eberhart v. United States, 546 U.S. 12 (2005)
Consumer WonFederal Rule of Criminal Procedure 33's deadline for filing motions for a new trial is a claim-processing rule rather than a jurisdictional one, meaning that noncompliance with the deadline can be waived and is not a bar to the district court's ability to consider the motion.