Law School Case Briefs
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Vermont Agency of Natural Resources v. United States Ex Rel. Stevens
Supreme Court of the United States (2000) | 146 L. Ed. 2d 836; 120 S. Ct. 1858; 529 U.S. 765; 2000 U.S. LEXIS 3428; 16 I.E.R. Cas. (BNA) 417; 2000 Cal. Daily Op. Serv. 3975; 2000 Daily Journal DAR 5319; 13 Fla. L. Weekly Fed. S 336; 2000 Colo. J. C.A.R. 2799; 68 U.S.L.W. 4399; 50 ERC (BNA) 1545
TL;DR: A private citizen sued a Vermont state agency under the False Claims Act. The Supreme Court held that while the citizen had standing as a partial assignee of the U.S. government's claim, the Act's term "person" does not include states, thus barring the suit.
Legal Significance: Established that *qui tam* relators have Article III standing based on a partial assignment theory, but shielded states from such suits by holding they are not "persons" under the False Claims Act, thereby avoiding a direct Eleventh Amendment ruling.