State ex rel. Phillip E. Edmondson v. Board of Trustees of Illinois Eastern Community Colleges

Illinois Appellate Court
Civil Court
False Claims Act
Citation
Case Number: 
2019 IL App (5th) 180333
Decision Date: 
Wednesday, August 14, 2019
District: 
5th Dist.
Division/County: 
St. Clair Co.
Holding: 
Affirmed; certified question answered.
Justice: 
CHAPMAN

Relator, a former instructor in the Defendant community college district's Workforce Education program, filed suit under the Illinois False Claims Act, and alleged that Defendant defrauded State of Illinois by claiming that miners took mine safety classes they never took, and by inflating the number of hours of training received by those who did take the classes. An entity included in the False Claims Act's broad definition of the "State" may be a "person" liable to another such entity unless the 2 entities are so closely intertwined that they are, in essence, a single entity. Because the defendant here is not an arm of the state, it is a "person" subject to potential liability to the State of Illinois under the False Claims Act. (CATES and BARBERIS, concurring.)