U.S. ex rel. Hanna v. City of Chicago

Federal 7th Circuit Court
Civil Court
False Claims Act
Citation
Case Number: 
No. 15-3305
Decision Date: 
August 22, 2016
Federal District: 
N.D. Ill., E. Div.
Holding: 
Affirmed

Dist. Ct. did not err in dismissing plaintiff’s amended False Claim Act action, alleging that defendant-City made false certifications to HUD that defendant was in compliance with certain federal requirements relating to its reduction of City’s racial housing segregation in order to obtain more than $1 billion in federal housing funds, where, according to plaintiff, defendant had in fact employed zoning and land use policies that increased residential housing segregation. Instant complaint failed to comply with special pleading requirements set forth in Rule 9(b), and plaintiff failed to plead any linkage between statutes at issue in relevant certifications and any particular false certification made by defendant. Ct. also noted that plaintiff failed to allege time, place and method by which alleged misrepresentation was communicated to him.