By David Darr
Today, in the civil case of United States ex rel. Prince v. Virginia Resources Authority, an unpublished per curiam opinion, the Fourth Circuit affirmed the decision of the District Court for Western District of Virginia dismissing the plaintiff’s qui tam action under the False Claims Act.
Plaintiff Contended the District Court Improperly Dismissed His Claims
On appeal, the plaintiff contended that the District Court’s dismissal of his qui tam action and subsequent denial of the plaintiff’s motion to alter judgment were reversible error.
The District Court’s Dismissal and Denial of Motion to Amend
Mark Prince brought a qui tam action under the False Claims Act on behalf of the federal government against Virginia Resources Authority (VRA) and other defendants. A qui tam action allows a whistleblower to sue on behalf of the government to recover money, and if successful, the plaintiff recovers some of that money too. Prince contended that VRA and other defendants issued bonds that violated the Virginia Constitution and that VRA falsely claimed that these bonds were legally issued. VRA filed a motion to dismiss for failure to state a claim and lack of jurisdiction because a Virginia state court already decided the issue that the bonds were legally issued in previous case that Prince brought. The District Court decision said that issue was precluded and collateral estoppel was appropriate because the parties at the proceedings were the same, the issue was actually litigated in the prior case, the issue was essential to the prior judgment, and the prior case reached final judgment. Applying collateral estoppel, the District Court dismissed Prince’s claim against VRA. With respect to the other defendants, the District Court dismissed the claims against them because they were never actually served.
In response to the adverse court ruling, Prince filed a “Motion to Reconsider.” The District Court construed this motion as a Rule 59(e) motion to amend judgment because there is no basis in the Federal Rules of Civil Procedure for Prince’s “Motion to Reconsider.” Because Prince’s motion only argued that the judgment was wrong, it was improper for the District Court to grant it. Prince’s motion was more along the lines of what an appellate court should decide. The District Court also clarified in its second opinion that the United States was not precluded from litigating the matter in the future because they were not a party to the original action.
An Appellate Court Reviews Decisions for Reversible Error
The Fourth Circuit’s role in this appeal was to find out whether the District Court made any reversible error.
The Fourth Circuit Found No Reversible Error
The Fourth Circuit reviewed the record from the District Court and agreed with its reasoning for dismissing the case and not allowing the plaintiff to alter the judgment. Therefore, the Fourth Circuit found that there was no reversible error committed by the District Court.
The Fourth Circuit Affirmed the Dismissal
The Fourth Circuit affirmed, holding that the District Court did not commit any reversible error.