Graham County Soil & Water Conservation District v. United States ex Rel. Wilson

PETITIONER: Graham County Soil & Water Conservation District, et al.
RESPONDENT: United States, ex rel. Karen T. Wilson
LOCATION: Texas State Capitol

DOCKET NO.: 04-169
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: United States Court of Appeals for the Fourth Circuit

CITATION: 545 US (2005)
GRANTED: Jan 07, 2005
ARGUED: Apr 20, 2005
DECIDED: Jun 20, 2005

ADVOCATES:
Christopher G. Browning, Jr. - argued the cause for Petitioners
Douglas Hallward-Driemeier - argued the cause for Respondent
Mark T. Hurt - argued the cause for Respondent

Facts of the case

The False Claims Act (FCA) allows the government or an individual on the government's behalf to sue any person for "making false or fraudulent claims for payment to the United States." A 1986 amendment to the FCA allows individuas to sue their employer if the employer retaliates against them in any way for assisting in an investigation of such false claims. In 2001, Karen Wilson, a secretary for Graham County Water District, sued her employer for various false claims it allegedly made concerning a federal disaster relief program. She also brought a retaliation suit against her employer, alleging that after she had provided information on the false claims to federal officials in December 1995, she had been repeatedly harassed by Graham County District officials until she resigned in March 1997. The District Court dismissed Wilson's suit as untimely. The court accepted Graham County District's argument that the six-year statute of limitations in the 1986 amendment to the FCA was not intended to apply to retaliation suits. Therefore, the court held, the most closely analogous state limitation applies instead. The north Carolina limit for retaliation suits was three years, so Wilson's suit was brought too late. On appeal, the Court of Appeals for the Fourth Circuit reversed the District Court and applied the six-year limitation to all retaliation suits under the FCA.

Question

Does the six-year statute of limitations in the False Claims Act apply to suits brought by individuals who were retaliated against by their employers for assisting an investigation of false or fraudulent claims?

Media for Graham County Soil & Water Conservation District v. United States ex Rel. Wilson

Audio Transcription for Oral Argument - April 20, 2005 in Graham County Soil & Water Conservation District v. United States ex Rel. Wilson

Audio Transcription for Opinion Announcement - June 20, 2005 in Graham County Soil & Water Conservation District v. United States ex Rel. Wilson

William H. Rehnquist:

The opinion of the Court in Graham County versus United States will be announced by Justice Thomas.

Clarence Thomas:

This case comes to us on a writ of certiorari to the United States Court of Appeals for the Fourth Circuit.

The False Claims Act prohibits submitting false claims for payment to the US Government.

It also prohibits employers from retaliating against employees who assist the government in investigating or prosecuting false claims actions and gives employees a private cause of action as a remedy.

The question we decide is whether the six year statute of limitations in the False Claims Act applies to such retaliation actions or whether instead the most closely analogous state statute of limitations applies?

This case began when respondent Karen T. Wilson brought a False Claims Act retaliation action against petitioner, Graham County Soil and Water Conservation District, a political subdivision of the state of North Carolina.

She alleged that County officials retaliated against her for aiding in a federal investigation whether County officials and others had made false claims to the United States.

The District Court concluded that Wilson's action was time barred because it was outside the 3-year statute of limitations specified by North Carolina law.

The Court of Appeals reversed the District Court's ruling.

It held that the False Claims Act's longer 6-year statute of limitations governed Wilson's retaliations action rather than the shorter state statute of limitations.

In an opinion filed with the Clerk today, we reverse the judgment of the Court of Appeals and remand for further proceedings.

If no federal statute of limitations expressly governs a federal cause of action, we generally borrow the most closely analogous state statute of limitations.

We think that no federal statute of limitations expressly governs False Claims Act retaliation actions and therefore hold that the most closely analogous state statute of limitations supplies the time limit.

The only possible federal statute of limitations applicable to retaliation claims is set forth in Section 3731(b)(1) of the False Claims Act.

It provides that the time limit for filing a cause of action begins to run on the date the defendant submits the false claim for payment.

For reasons we explain in detail in the opinion, we find that this statute's text is ambiguous about whether it governs the retaliations actions.

We resolve this ambiguity primarily using a rule of statutory construction, the presumption that statues of limitation begin to run when the cause of action arises.

If section 3731(b)(1) governs retaliations actions, then the limitations period will begin to run before the cause of action arises contrary to our presumption.

By contrast, if we borrow the most closely analogous state limitations period, the time limit will begin when the cause of action accrues in keeping with our presumption.

We therefore conclude that the most closely analogous state limitations period governs False Claims Act retaliations claims.

Justice Souter joins all of the opinion except for footnote two; Justice Stevens has filed an opinion concurring in the judgment; Justice Breyer has filed a dissenting opinion in which Justice Ginsburg joins.