US Court of Appeals for the Fifth Circuit Opinions
United States ex rel. Vaughn v. United Biologics, LLC
Opinion Date: September 7, 2018
Judge: Edith Brown Clement
Areas of Law: Civil Procedure, Government & Administrative Law
The Fifth Circuit affirmed the district court's dismissal with prejudice as to relators and without prejudice as to the Government in an action under the False Claims Act (FCA). The court held that the district court did not err by dismissing the Government without prejudice when relators sought to abandon their claims. The court explained that relators acted on purely private interests and the Government, even one that chose not to intervene, should not be bound by that decision, because it was powerless to vindicate the public's interests in other actions that may have a stronger basis or a relator more able to shoulder the burdens of litigation. The court rejected United's remaining claims regarding relators' voluntary dismissal and held that the district court did not abuse its discretion.
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