Narrative Opinion Summary
In a case regarding fraud allegations against Redflex Traffic Systems, Inc. (RTSI), a former Vice President, Aaron Rosenberg, sought a share of settlement proceeds related to a fraud case he helped facilitate. Rosenberg's claims were dismissed by the district court on the basis that he was neither the original source of the fraud allegations nor a volunteer under the Chicago False Claims Ordinance (FCO). He appealed this decision. The case involved RTSI's contract with the City of Chicago for a red-light enforcement program and subsequent revelations of misconduct involving city officials and RTSI executives, including bribery schemes. The court applied the FCO's public disclosure bar, emphasizing that the allegations were already public through various media reports prior to Rosenberg filing his complaint and that his disclosures were not voluntary. Consequently, Rosenberg did not qualify as an original source. Additionally, the court found Rosenberg lacked jurisdictional standing to claim a share of the settlement or attorney’s fees, as the City intervened in the lawsuit, reinforcing the public disclosure bar's application. The district court's judgment was affirmed, denying Rosenberg's appeal and his claims for settlement and fees.
Legal Issues Addressed
Jurisdictional Standing under the False Claims Ordinancesubscribe to see similar legal issues
Application: The court ruled that Rosenberg lacked jurisdictional standing to act as a relator due to the public disclosure bar, thus denying his entitlement to settlement proceeds and attorney’s fees.
Reasoning: Since the City intervened in the action and Rosenberg is barred from acting as relator under this provision, he is no longer considered the individual bringing the action.
Original Source Requirement for Qui Tam Actionssubscribe to see similar legal issues
Application: Rosenberg's claim as a relator was denied due to his inability to prove voluntary disclosure of information to the city, as his disclosures were made in response to a government inquiry.
Reasoning: His failure to initiate contact and the fact that he only disclosed information during the City’s investigation indicate that his participation does not meet the FCO's criteria for a voluntary disclosure.
Public Disclosure Bar under the Chicago Fraud Control Ordinancesubscribe to see similar legal issues
Application: The court applied the public disclosure bar to dismiss Rosenberg's claim, finding that the allegations were publicly disclosed prior to Rosenberg's filing and that he failed to qualify as an original source.
Reasoning: The district court established that they were, citing multiple Chicago Tribune articles published as early as October 2012 regarding a bribery scheme involving Redflex, Bills, and O’Malley.