U.S. ex rel. Marshall v. Woodward, Inc.

Dist. Ct. did not err in granting defendants’ motion for summary judgment in qui tam action under False Claims Act, alleging that defendants falsely certified that helicopter engine part that was sold to U.S. govt. met applicable standards and that defendants terminated them in retaliation for lodging complaints that said part did not meet applicable standards. Plaintiffs failed to establish knowledge element required for False Claims Act claim, since record failed to contain any evidence that applicable decision-maker believed merits of plaintiffs’ concerns about said helicopter part, and since defendants actually took plaintiffs’ concerns seriously by undergoing two investigations that ultimately did not support plaintiffs’ allegations. Thus, plaintiffs’ failed to show that decision-maker had knowledge that certifications to govt. were false at time they were made. Moreover, fact that govt. continued to accept helicopter part after plaintiffs informed govt. of their concerns indicates that alleged false certifications were immaterial. Plaintiffs also could not prevail on their retaliation claim, where: (1) defendants explained that plaintiffs were terminated because they were insubordinate; and (2) record showed that plaintiffs were actually insubordinate in failing to resume working on said helicopter part in face of multiple direct commands to do so.