Battle v. Board of Regents for the State of Georgia

Lillie Battle (plaintiff) was an employee in the Office of Financial Aid and Veterans Affairs (OFA) at Fort Valley State University, a state-funded university in Georgia. Battle was a financial-aid counselor, and her duties required Battle to check the accuracy of student financial-aid files. Battle found what she believed to be fraud in some student files. Battle notified her direct supervisor, Jeannette Huff, of the irregularities Battle found, but Huff took no action. Battle reported these irregularities to the university’s Vice-President for Student Affairs, Cynthia Sellers, and the university’s President, Oscar Prater. Neither Sellers nor Prater took any action. Battle was subsequently notified that her employment contract for her position would not be renewed. After learning that her contract was not renewed, Battle reported the financial-aid irregularities to the United States Department of Education (USDOE). The USDOE investigated Battle’s allegations and found that the university had failed to comply with federal student-aid regulations. Subsequent government audits continued to find issues of noncompliance. The university eventually reached a financial settlement with USDOE. Battle filed a lawsuit against the university, Huff, Sellers, and Prater, arguing that she was terminated for reporting the fraud Battle found in violation of her First Amendment rights. Battle also argued that Huff, Sellers, and Prater submitted false claims to the United States government in violation of the False Claims Act. Battle pointed to violations in government audits of the university’s financial-aid files to support this claim. The district court granted summary judgment to the university, Huff, Sellers, and Prater on all claims. Battle appealed.