U.S. ex rel. Heath v. Wisconsin Bell, Inc.

Dist. Ct. erred in dismissing for lack of jurisdiction plaintiff’s qui tam action under False Claims Act, alleging that defendant overcharged certain school districts for telecommunication services it provided under Education Rate Program, where Dist. Ct. found that plaintiff’s action was barred under public disclosure doctrine due to fact that plaintiff had relied on information contained in Wisc. Dept. of Administration’s web site. Public disclosure doctrine did not apply, since plaintiff alleged that he had used independent investigation and analysis to discover discrepancy in defendant’s charges for telecommunications, and since information contained in web site would not have alerted anyone to fact that defendant might have overcharged any school district without knowledge of facts developed by plaintiff.