Rockwell Int'l Corp. v. United States, 549 U.S. 457 (2007)
Primary Holding
The False Claims Act bars federal-court jurisdiction over actions based on publicly disclosed allegations unless the action is brought by the Attorney General or the plaintiff is an original source of the information.
In the case of Rockwell International Corp. v. United States, the Supreme Court decided that if someone wants to sue a company for fraud based on information that is already public, they can only do so if they are the original source of that information or if the government is the one bringing the case. This matters because it helps prevent people from making claims based on rumors or information that is already out there, ensuring that only credible sources can hold companies accountable. For consumers, this ruling protects their rights by making sure that legal actions against companies for fraud are based on solid evidence, which can lead to more reliable outcomes. This case is relevant if you suspect a company is committing fraud but only have access to information that has already been publicly disclosed; you would need to be the original source of that information to take legal action.
AI-generated plain-language summary to help you understand this case
In Rockwell International Corp. v. United States, the underlying dispute centers around the management of the Rocky Flats nuclear weapons plant in Colorado, which Rockwell International operated under a contract with the Department of Energy (DOE) from 1975 to 1989. During this period, Rockwell explored a method for disposing of toxic pond sludge by mixing it with cement to create "pondcrete" blocks. James Stone, an engineer at the plant from 1980 to 1986, raised concerns about the proposed manufacturing process, predicting that it would result in an unstable mixture that could lead to environmental contamination. Despite his warnings, Rockwell proceeded with the project, and after Stone's departure, it was discovered that many of the pondcrete blocks were "insolid" and leaking, raising significant environmental concerns. The procedural history of the case involves a False Claims Act lawsuit brought by James Stone against Rockwell International, alleging that the company knowingly submitted false claims to the government regarding the safety and integrity of the pondcrete blocks. The case eventually reached the Supreme Court after the Tenth Circuit Court of Appeals addressed the issue of whether Stone qualified as an "original source" of the information related to the claims, which is a key factor in determining the jurisdiction of the federal courts under the False Claims Act. The background context highlights the complexity and duration of the litigation, which spans nearly two decades. The case underscores significant issues related to environmental safety, corporate accountability, and the legal standards governing whistleblower protections under the False Claims Act. Stone's allegations were initially based on his firsthand knowledge and experience at the Rocky Flats plant, raising questions about the extent of Rockwell's awareness of the pondcrete's deficiencies and the potential implications for public health and safety.
Whether James Stone was an "original source" of information under the False Claims Act, thereby allowing him to maintain a lawsuit despite the public disclosure of allegations related to Rockwell International Corp.'s conduct.
The judgment is vacated and remanded for a determination whether Stone was in fact an original source of the allegations publicly disclosed by the media in 1988 and 1989.
- Court
- Supreme Court
- Decision Date
- December 5, 2006
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Scalia
- Damages Awarded
- N/A
- Data Quality
- high
Allison Engine Co. v. United Statesex rel. Sanders, 553 U.S. 662 (2008)
Consumer LostA plaintiff asserting a claim under the False Claims Act must prove that the defendant intended for the false record or statement to be material to the Government's decision to pay or approve the false claim.
John R. Sand & Gravel Co. v. United States, 552 U.S. 130 (2008)
Consumer LostA court must consider the timeliness of a lawsuit filed in the Court of Federal Claims, even if the government waives the issue, due to the special statute of limitations that governs claims in that court.
United States v. Atlantic Research Corp., 551 U.S. 128 (2007)
Consumer WonPotentially responsible parties (PRPs) under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) may recover cleanup costs from other PRPs through a cause of action provided by §107(a).
Wilkie v. Robbins, 551 U.S. 537 (2007)
Consumer LostA landowner does not have a private right of action for damages under Bivens or a claim against federal officials in their individual capacities under the Racketeer Influenced and Corrupt Organizations Act (RICO) for harassment and intimidation aimed at extracting an easement across private property.