Campbell v. Redding Medical Center

On October 30, 2002, the Federal Bureau of Investigation (FBI) announced that it had secured a medical-records search warrant to investigate Redding Medical Center (RMC) (defendant) and RMC doctors (defendants) after accusations that RMC had engaged in a scheme to fraudulently bill Medicare by performing thousands of unnecessary cardiac procedures. On November 5, 2002, a former RMC patient submitted a complaint against RMC and RMC doctors under the qui tam provision of the False Claims Act (FCA). On November 8, 2002, Patrick Campbell (plaintiff) submitted a similar complaint. The qui tam provision grants authority to private parties to sue individuals who have committed government fraud on behalf of the government and rewards the complainant up to 25 percent of the government’s recovery. However, the FCA provided that to receive the reward, the complainant must have been the original source and must have been the first to file. An original source is a party who had independent knowledge of the fraudulent activities and provided the information to the government before filing the claim. The FCA provided that if a party was not the original source, then the court must dismiss the case for a lack of jurisdiction. The first-to-file rule favors the first private party to file the claim. The government moved to dismiss Campbell’s complaint under the first-to-file rule. The district court granted the motion to dismiss. Campbell appealed.