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Monday, June 09, 2008

U. S. Supreme Court Issues Opinions Today.

The first case is ENGQUIST v. OREGON DEPARTMENT OF AGRICULTURE ET AL, 07-474 (2008). According to the court:

The question in this case is whether a public employee can state a claim under the Equal Protection Clause by alleging that she was arbitrarily treated differently from other similarly situated employees, with no assertion that the different treatment was based on the employee’s membership in any particular class. We hold that such a
“class-of-one” theory of equal protection has no place in the public employment context.

In the second case, QUANTA COMPUTER, INC., ET AL. v. LG ELECTRONICS, INC., 06-937 (2008). The court was unanimous in finding that:

For over 150 years this Court has applied the doctrine of patent exhaustion to limit the patent rights that survive the initial authorized sale of a patented item. In this case, we decide whether patent exhaustion applies to the sale of components of a patented system that must be combined with additional components in order to practice the patented methods. The Court of Appeals for the Federal Circuit held that the doctrine does not apply to method patents at all and, in the alternative, that it does not apply here because the sales were not authorized by the license agreement. We disagree on both scores. Because the exhaustion doctrine applies to method patents, and because the license authorizes the sale of components that substantially embody the patents in suit, the sale exhausted the patents.

In the third case, BRIDGE ET AL. v. PHOENIX BOND & INDEMNITY CO. ET AL., 07-210 (1980), which involves Cook County Treasurer’s Office's public auction to sell its tax liens on delinquent taxpayers’ property, the court held:

The Racketeer Influenced and Corrupt Organizations Act (RICO or Act), 18 U. S. C. §§1961–1968, provides aprivate right of action for treble damages to “[a]ny person injured in his business or property by reason of a violation” of the Act’s criminal prohibitions. §1964(c). The question presented in this case is whether a Plaintiff asserting a RICO claim predicated on mail fraud must plead and prove that it relied on the defendant’s alleged misrepresentations. Because we agree with the Court of Appeals that a showing of first-party reliance is not required, we affirm.

and, in the fourth case, ALLISON ENGINE CO., INC., ET AL. v. UNITED STATES EX REL. SANDERS ET AL, 07-214 (2008), a unanimous court held as follows:

The False Claims Act (FCA) imposes civil liability on any person who knowingly uses a “false record or statement to get a false or fraudulent claim paid or approved by the Government,” 31 U. S. C. §3729(a)(2), and any person who “conspires to defraud the Government by getting a false or fraudulent claim allowed or paid,” §3729(a)(3). We granted review in this case to decide what a plaintiff asserting a claim under these provisions must show regarding the relationship between the making of a “false record or statement” and the payment or approval of “a false or fraudulent claim . . . by the Government.”

Contrary to the decision of the Court of Appeals below, we hold that it is insufficient for a plaintiff asserting a §3729(a)(2) claim to show merely that “[t]he false statement’s use . . . result[ed] in obtaining or getting payment or approval of the claim,” 471 F. 3d 610, 621 (CA6 2006)or that “government money was used to pay the false or fraudulent claim,” id., at 622. Instead, a plaintiff asserting a §3729(a)(2) claim must prove that the defendant intended that the false record or statement be material to the Government’s decision to pay or approve the false claim. Similarly, a plaintiff asserting a claim under §3729(a)(3) must show that the conspirators agreed to make use of the false record or statement to achieve this end.

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