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Supreme Court rules in False Claims Act, patent, discrimination and RICO cases

[JURIST] The US Supreme Court [official website; JURIST news archive] handed down four decisions Monday, including Allison Engine v. United States [JURIST report], where the Court ruled that the Federal False Claims Act [31 USC 3729 text] is not limited to claims of misspent funds submitted to a federal government agency, but also applies to claims submitted to a federal contractor that will ultimately be paid with federal money. The Court upheld a US Court of Appeals for the Sixth Circuit ruling [opinion, PDF], finding that the statute requires only "that the defendant made a false record or statement for the purpose of getting 'a false or fraudulent claim paid or approved by the Government.'" Read the Court's unanimous opinion [text] per Justice Alito. AP has more.

In Quanta v. LG [Duke Law backgrounder; JURIST report], the Court ruled that a patent holder's rights may be exhausted through certain license agreements. LG Electronics held a patent on certain computer components, but had an agreement with Intel Corp. [corporate websites] that let Intel manufacture those parts. Quanta Computer [corporate website] bought the patented parts from Intel and used them to make notebook computers. LG Electronics sued Quanta, arguing that Quanta infringed its patents not by buying the parts but by using them to make computers. The ruling overturns a July 2006 US Court of Appeals for the Federal Circuit decision [opinion, PDF], with the Court finding that "the authorized sale of an article that substantially embodies a patent exhausts the patent holder’s rights and prevents the patent holder from invoking patent law to control postsale use of the article." Read the Court's unanimous opinion [text] per Justice Thomas. AP has more.

In Engquist v. Oregon Dept. of Agriculture [Duke Law backgrounder; JURIST report], the Court ruled that a federal employee who is not a member of a protected class can not sue for discrimination that was directed solely against her. The Ninth Circuit Court held [opinion, PDF] that an Indian-born woman who alleged discrimination from her supervisor could not sue under a "class-of-one theory." The Court reversed, finding that "the practical problem with allowing class-of-one claims to go forward in this context is not that it will be too easy for plaintiffs to prevail, but that governments will be forced to defend a multitude of such claims in the first place, and courts will be obliged to sort through them in a search for the proverbial needle in a haystack." Read the Court's opinion per Justice Roberts, and a dissent [texts] from Justice Stevens, who was joined by Justices Souter and Ginsburg. AP has more.

In Bridge v. Phoenix Bond & Indemnity [Duke Law backgrounder; JURIST report], the Court ruled that a victim of mail fraud does not need to prove that he relied on a misrepresentation made by the defendant to prevail in a civil Racketeer Influenced and Corrupt Organizations Act (RICO) [text] action, holding "RICO’s text provides no basis for imposing a first-party reliance requirement." The ruling affirms a decision [PDF text] by the Seventh Circuit Court of Appeals. Read the Court's unanimous opinion [text] per Justice Thomas.

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