Cause of Action v. Chicago Transit Authority

Dist. Ct. did not err in dismissing plaintiff’s False Claims Act claim against defendant, alleging that defendant misreported transit data to Federal Transit Administration in order to secure inflated federal grant allocations, where basis for dismissal was finding that instant case fell within public disclosure bar under section 3730(e)(4) of False Claims Act. Record showed that plaintiff’s allegations had been publicly disclosed in Technical and Audit reports that had been previously tendered to govt., that instant action was based on information disclosed in said reports, and that plaintiff could not establish that it was original source of fraud allegations contained in said reports. Fact that complaint contained two additional claims did not require different result, where one claim was based on inference drawn from facts contained in reports and other claim pertained to same fraudulent conduct as publicly disclosed information.