United States of America, ex rel. Elizabeth Koehler, The States of California, Florida, Massachusetts, and New York, ex rel. Elizabeth Koehler, and Elizabeth Koehler, individually v. United Site Services, Inc.

CourtDistrict Court, E.D. New York
DecidedMarch 30, 2026
Docket1:17-cv-07083
StatusUnknown

This text of United States of America, ex rel. Elizabeth Koehler, The States of California, Florida, Massachusetts, and New York, ex rel. Elizabeth Koehler, and Elizabeth Koehler, individually v. United Site Services, Inc. (United States of America, ex rel. Elizabeth Koehler, The States of California, Florida, Massachusetts, and New York, ex rel. Elizabeth Koehler, and Elizabeth Koehler, individually v. United Site Services, Inc.) is published on Counsel Stack Legal Research, covering District Court, E.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States of America, ex rel. Elizabeth Koehler, The States of California, Florida, Massachusetts, and New York, ex rel. Elizabeth Koehler, and Elizabeth Koehler, individually v. United Site Services, Inc., (E.D.N.Y. 2026).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK

UNITED STATES OF AMERICA, ex rel. ELIZABETH KOEHLER, THE STATES OF CALIFORNIA, FLORIDA, MASSACHUSETTS, and NEW YORK, ex rel. ELIZABETH KOEHLER, and ELIZABETH KOEHLER, individually, MEMORANDUM AND ORDER

Plaintiffs, 17-CV-07083-LDH-LKE v.

UNITED SITE SERVICES, INC.,

Defendant.

LASHANN DEARCY HALL, United States District Judge: Elizabeth Koehler (“Relator”) brings this qui tam action against United Site Services, Inc. (“Defendant”), individually and on behalf of the United States of America and the States of California, Florida, Massachusetts, and New York (the “States”), alleging claims under the False Claims Act (“FCA”) and analogous state laws (“State FCA Laws”).1 Defendant moves, pursuant to Rules 9(b), 12(b)(2),2 and 12(b)(6) of the Federal Rules of Civil Procedure, to dismiss Relator’s non-intervened federal FCA and state FCA claims.

1 Pursuant to 31 U.S.C. § 3730(b)(4)(B), the United States declined to intervene as to the counts brought under the FCA. The States also declined to intervene as to the counts brought pursuant to State FCA Laws. 2 Although Defendant only expressly moves to dismiss on Rules 9(b) and 12(b)(6) of the Federal Rules of Civil Procedure, Defendant also advances arguments with respect to personal jurisdiction over it in the instant matter. The Court, therefore, construes Defendant’s motion as also brought pursuant to Rule 12(b)(2) of the Federal Rules of Civil Procedure. BACKGROUND3 I. The Multiple Award Schedule Defendant leases and services portable restrooms, restroom trailers, shower trailers, roll off trash containers, and temporary fences. (Corrected Am. Compl. (“Am. Compl.”) ¶ 2, ECF

No. 42.) In addition, Defendant provides waste-pumping and temporary electric power services. (Id.) According to the Corrected Amended Complaint (the “Amended Complaint”), Defendant provides its services in all states, the District of Columbia, and United States territories.4 (Id. ¶ 42; see also id. ¶¶ 5-6.) On August 1, 2007, Defendant entered a Multiple Award Schedule (the “Schedule”) with the Government Services Administration (the “GSA”), which acted on behalf of the United States. (Id. ¶ 38.) Pursuant to the Schedule, Defendant contracted with “Government agencies,” to act as a general or prime contractor, to transport, set up, and service portable restrooms, restroom trailers, shower trailers, and hand-washing units in all states, the District of Columbia,

and United States territories through 2012. (Id. ¶¶ 39-40, 42, 44; see also id. ¶ 49 n. 3 (“Defendant contracted with agencies of the federal government . . . . ”).) In 2012, the United States extended Defendant’s contract for an additional five-year period. (Id. ¶ 41.) Pursuant to Sections 52.222-6 and 52.222-41 of the Schedule, Defendant and any subcontractor were required to comply with the prevailing wage and the “minimum labor standards,” as established under the Davis-Bacon Act and the Service Contract Act, respectively. (Id. ¶¶ 30, 35, 45-46.)

3 The following facts are taken from the Corrected Amended Complaint (the “Amended Complaint”), (Corrected Am. Compl. (“Am. Compl.”), ECF No. 42), and, unless otherwise indicated, are assumed to be true for the purposes of this memorandum and order 4 The Amended Complaint contains inconsistent allegations as to the areas that Defendant services. In one instance, Relator alleges that Defendant provides services in the forty-eight contiguous states and the District of Columbia. (Id. ¶¶ 5-6.) In another, Relator alleges that Defendant provides services in all states, the District of Columbia, and the United States territories. For the purposes of this memorandum, the Court accepts the latter allegation as true. (Id. ¶ 42.) Moreover, pursuant to the Schedule, wage determinations were to be made by the Department of Labor, representing the prevailing wage that Defendant and any subcontractor were required to pay each classification of workers. (Id. ¶¶ 47-48.) Additionally, while the Amended Complaint fails to identify when, at some point, Defendant contracted with the States of Texas, Florida, Massachusetts, Washington, Colorado,

New York, and California to transport, set up, and service portable restrooms, restroom trailers, shower trailers, and hand-washing units. (Id. ¶ 49.) According to the Amended Complaint, these contracts contained provisions “similar to those contained within” the contracts that Defendant entered with federal agencies. (Id. ¶ 50.) Defendant’s National Government Account Manager, as well as other members of its senior management team, were responsible for negotiating and managing the “[g]overnment contracts”5 awarded to Defendant. (Id. ¶ 53.) Relator was employed by Defendant from November 2011 to June 2016 as the Regional Sales Manager for Defendant’s South Central Region, including the States of Texas, Louisianna, Mississippi, and Alabama. (Id. ¶ 59.) In that

capacity, Relator worked closely and frequently with Defendant’s senior management team, to ensure that government contracts were adequately serviced. (Id. ¶¶ 54, 59; see id. ¶ 55.) In her role, Relator oversaw all revenue generated by United Site Service in the South Central region and resolved complaints lodged by customers, including complaints that Defendant automatically billed them for missed service calls and “lack of service verification.” (Id. ¶¶ 60, 62.) Relator, however, did not approve government contracts; rather, only members of Defendant’s senior management and legal teams were authorized to do so. (Id. ¶¶ 56-58.)

5 In certain instances, the Amended Complaint fails to distinguish between contracts entered by Defendant with federal agencies and those entered with the states, referring instead only to “[g]overnment contracts.” (See, e.g., id. ¶ 52.) A. Missed Service Calls Defendant employed approximately one hundred delivery drivers, whose duties included the pickup and delivery of portable restrooms, restroom trailers, shower trailers, and hand- washing units that Defendant provided to worksites, pursuant to its government contracts. (Id. ¶ 64.) Defendant also employed nearly five hundred tanker-truck and pump-truck drivers, whose

primary responsibility was to pump, maintain, and service the portable restrooms, restroom trailers, and hand-washing units at each worksite. (Id. ¶ 66.) Additionally, Defendant scheduled up to 1,800 services per day, in any given market. (Id. ¶ 67.) Prior to servicing the worksites, each pump-truck and tanker-truck driver was assigned a service route via a service sheet, which provided the schedule for the customers being serviced that day. (See id. ¶ 79.) Drivers that missed a scheduled service were required to physically mark the missed service on their service sheet and state the reason for the missed service. (Id. ¶ 80.) At the end of each day, the drivers submitted their route sheets to a dispatcher, who in turn sent the sheets to Defendant’s Field Operations Support (the “FOS”) office in California. (Id. ¶¶ 82-83.) The FOS office analyzed

the drivers’ route sheets and, in instances of missed service calls, was responsible for rescheduling services for the following day. (Id. ¶¶ 86-87.) Defendant’s clients, including “the [g]overnment,” were automatically billed for a set number of services per week, as set forth in each client’s contract. (Id.

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United States of America, ex rel. Elizabeth Koehler, The States of California, Florida, Massachusetts, and New York, ex rel. Elizabeth Koehler, and Elizabeth Koehler, individually v. United Site Services, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-of-america-ex-rel-elizabeth-koehler-the-states-of-nyed-2026.