SARGENT v. MCDONOUGH

District Court, D. Maine·Decided December 18, 2024·No. 1:23-cv-00328·Unknown

Opinion

UNITED STATES DISTRICT COURT

DISTRICT OF MAINE

UNITED STATES ex rel. ERIK K. ) SARGENT, ) ) Plaintiff, ) ) v. ) No. 1:23-cv-00328-SDN ) DENIS McDONOUGH, Secretary ) DEPARTMENT OF VETERANS ) AFFAIRS, et al., ) ) Defendants. )

ORDER ON MOTION TO DISMISS

The matter returns on Defendant Denis McDonough’s, Secretary of the Department of Veterans Affairs (“VA”), second Motion to Dismiss (ECF No. 12). The Motion targets the sole remaining claim in this action which Plaintiff Erik Sargent (“Plaintiff”) presses against Secretary McDonough under the anti-retaliation provision of the False Claims Act (“FCA”), 31 U.S.C. § 3730(h).1

1 The FCA does not authorize claims against individual supervisors for their role in FCA-related retaliation, so Secretary McDonough would be the only viable defendant on the § 3730 claim, not the other, previously dismissed, individual defendants. United States ex rel. Strubbe v. Crawford Cnty. Mem’l Hosp., 915 F.3d 1158, 1167 (8th Cir. 2019); Howell v. Town of Ball, 827 F.3d 515, 529-30 (5th Cir. 2016); United States ex rel. Karvelas v. Tufts Shared Servs., Inc., 433 F. Supp. 3d 174, 180-81 (D. Mass. 2019); Orell v. UMass Mem’l Med. Ctr., Inc., 203 F. Supp. 2d 52, 66 (D. Mass. 2002); Laborde v. Rivera-Dueno, 2011 WL 814965, at *1 (D.P.R. Mar. 4, 2011); see also Rangarajan v. Johns Hopkins Health Sys. Corp., 2014 WL 6666308, at *4-6 (D. Md. Nov. 21, 2014) (collecting cases). I. Background

In his First Amended Complaint, Plaintiff alleges he was an employee of the VA Maine Healthcare System with authority to approve overtime for the Sensory and Rehabilitation Service Line (ECF No. 5, ¶¶ 15, 26, 28). Plaintiff approved overtime for an employee he refers to as “BF,” who performed Community Care physical therapy consults for overtime compensation (ECF No. 5, ¶¶ 26, 86-87).

Plaintiff alleges in August of 2021, he learned that BF had reached her overtime cap for the year and was not eligible for any further overtime unless the overtime was COVID-related, which the Community Care consults BF was performing were not (ECF No. 5, ¶ 93). Plaintiff further alleges he also learned BF had not been logging onto her computer during the time she claimed she was performing the Community Care consults and was instead conducting the consults during her regular work hours while claiming they were done on overtime (ECF No. 5, ¶¶ 99, 128).

According to Plaintiff, the Medical Center Director (previously dismissed Defendant Tracye Davis) and the Chief of Staff of VA Maine (previously dismissed Defendant Todd Stapley) signed a “false waiver” of BF’s overtime, deeming it “mission essential” to COVID and resulting in payment to BF of approximately $95,000 in overtime for which she was not eligible and did not actually work (ECF No. 5, ¶¶ 115, 117, 128, 136, 154). Plaintiff claims that, because he would not sign off on the waiver to approve BF’s overtime as COVID-related, he was “demoted, harassed, and in other matters

discriminated against in the terms and conditions of his employment” (ECF No. 5, ¶ 174). Plaintiff filed his Complaint on August 24, 2023 (ECF No. 1), and his First Amended Complaint, see Fed. R. Civ. P. 15(a)(1)(A), on September 22, 2023 (ECF No. 5). The United States intervened in the matter on November 16, 2023, and moved to dismiss Count I of the First Amended Complaint for False Claim and Conspiracy under 31 U.S.C. § 3729(a)(1)(A)-(C), (ECF No. 6), which this Court granted on February 26, 2024 (ECF

No. 9). The United States now moves to dismiss Sargent’s remaining claim under the anti- retaliation provision of the FCA, 31 U.S.C. § 3730(h) (ECF No. 12). II. Discussion A. Motion to Dismiss Standard

The United States moves to dismiss under Rule 12(b)(1) for lack of subject-matter jurisdiction. See Fed. R. Civ. P. 12(b)(1). “Federal courts are of limited jurisdiction[,]” Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375, 377 (1994), and the “party invoking the jurisdiction of a federal court carries the burden of proving its existence[,]” Murphy v. United States, 45 F.3d 520, 522 (1st Cir. 1995) (quoting Taber Partners, I v. Merit Builders, Inc., 987 F.2d 57, 60 (1st Cir. 1993)). On a “sufficiency challenge” to

subject-matter jurisdiction, the inquiry is whether the plaintiff has “propounded an adequate basis for subject-matter jurisdiction.” Valentin v. Hosp. Bella Vista, 254 F.3d 358, 363 (1st Cir. 2001). The Court credits the Plaintiff’s well-pleaded factual allegations and draws all reasonable inferences in Plaintiff’s favor to dispose of the challenge. Id. The Court may consider materials beyond the pleadings on a motion to dismiss for lack of subject-matter jurisdiction. See id. B. False Claims Act

The False Claims Act, 31 U.S.C. § 3729 et seq., authorizes civil penalties against persons who submit false claims for payment to the United States. 31 U.S.C. § 3729(a)(1). The FCA permits private persons to bring civil actions for false claims on behalf of themselves and the United States, called a qui tam action. Id. § 3730. If the suit is successful in recovering civil penalties for the United States, the qui tam plaintiff is awarded a portion of the penalties. Id. § 3730(d). The private person who brings a qui tam false claims action is referred to as a “relator.” Daly v. Dep’t of Energy, 741 F.Supp. 202, 203 (D. Colo. 1990). When a relator files a qui tam false claims case, the Government may intervene and control the case and is not bound by the acts of the relator. 31 U.S.C. §

3730. Due to their access to inside information, the private persons most likely to bring qui tam false claims cases are employees of government contractors. Daly, 741 F.Supp. at 203. The anti-retaliation provision, under which Plaintiff brings this claim, protects relators from retaliation by their employers. 31 U.S.C. § 3730(h) (“Any employee, contractor, or agent shall be entitled to all relief necessary to make that employee, contractor, or agent whole . . . .”).

C. Analysis Secretary McDonough asserts the FCA does not permit Plaintiff to pursue his retaliation lawsuit against the United States because Plaintiff is a federal employee and, as such, Plaintiff’s sole legal recourse is in the Civil Service Reform Act, 5 U.S.C. §§ 1214

Free access — add to your briefcase to read the full text and ask questions with AI

SARGENT v. MCDONOUGH, (D. Me. 2024).

SARGENT v. MCDONOUGH (SARGENT v. MCDONOUGH) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

United States v. Sherwood
312 U.S. 584 (Supreme Court, 1941)
United States v. Cooper Corp.
312 U.S. 600 (Supreme Court, 1941)
Land v. Dollar
330 U.S. 731 (Supreme Court, 1947)
Dugan v. Rank
372 U.S. 609 (Supreme Court, 1963)
United States v. King
395 U.S. 1 (Supreme Court, 1969)
United States v. Testan
424 U.S. 392 (Supreme Court, 1976)
Kokkonen v. Guardian Life Insurance Co. of America
511 U.S. 375 (Supreme Court, 1994)
Taber Partners, I v. Merit Builders, Inc.
987 F.2d 57 (First Circuit, 1993)
Murphy v. United States
45 F.3d 520 (First Circuit, 1995)
Valentin-De-Jesus v. United Healthcare
254 F.3d 358 (First Circuit, 2001)
Muirhead v. Mecham
427 F.3d 14 (First Circuit, 2005)
Juliano v. Federal Asset Disposition Ass'n (FADA)
736 F. Supp. 348 (District of Columbia, 1990)
Daly v. Department of Energy
741 F. Supp. 202 (D. Colorado, 1990)
Orell v. UMass Memorial Medical Center, Inc.
203 F. Supp. 2d 52 (D. Massachusetts, 2002)
Thomas Howell v. Town of Ball
827 F.3d 515 (Fifth Circuit, 2016)