Graham County Soil & Water Conservation Dist. v. US ex rel. Wilson, No. 08-304, concerned an action claiming that county conservation districts and local and federal officials knowingly submitted false payment claims to the U.S. in violation of the False Claims Act. The Supreme Court reversed the Fourth Circuit's reversal of the district court's dismissal of the action for lack of jurisdiction, holding that the reference to "administrative" reports, audits, and investigations contained in 31 U.S.C. section 3730(e)(4)(A) (the FCA's public disclosure bar) encompasses disclosures made in state and local sources, as well as federal sources.
As the Court wrote: "The False Claims Act (FCA) authorizes both the Attorney General and private qui tam relators to recover from persons who make false or fraudulent payment claims to the United States, but it bars qui tam actions based upon the public disclosure of allegations or transactions in, inter alia, "a congressional, administrative, or Government Accounting Office [(GAO)] report, hearing, audit, or investigation." 31 U. S. C. §3730(e)(4)(A). Here, federal contracts provided that two North Carolina counties would remediate areas damaged by flooding and that the Federal Government would shoulder most of the costs. Respondent Wilson, then an employee of a local government body involved in this effort, alerted local and federal officials about possible fraud. Both the county and the State issued reports identifying potential irregularities in the contracts' administration. Subsequently, Wilson filed a qui tam action, alleging, as relevant here, that petitioners, county conservation districts and local and federal officials, knowingly submitted false payment claims in violation of the FCA."