U.S. ex rel. Ziebell v. Fox Valley Workforce Development Bd. Inc.

Dist. Ct. lacked jurisdiction over plaintiff’s qui tam action alleging that defendant-plaintiff’s former employer violated False Claims Act by improperly contracting services through subsidiary corporation and then falsely claiming that they satisfied all requirements necessary to receive federal funds. Record showed that any improprieties by defendant were previously revealed in audit of defendant, which counts as prior “public disclosure” under False Claims Act that precluded plaintiff from bringing instant action. Moreover, plaintiff failed to establish that she was original source of information that formed basis of audit finding.