U.S. ex rel. Baltazar v. Warden

Dist. Ct. erred in dismissing plaintiff's qui tam action under False Claims Act, alleging that plaintiff's employer submitted fraudulent bills to Medicare and Medicaid programs, where Dist. Ct. found that plaintiff's lawsuit was based on information already in public domain. While 2005 Inspector General's report already concluded that 57% of all chiropractors' claims to Medicare were for services that were not performed and another 16% of said bills were inflated, instant claim could still proceed since plaintiff's contention that defendants submitted intentionally false claims was based on plaintiff's own knowledge about defendant's practices that were not identified in said report.