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Steven Zorn, et al. v. Stephen B. Grant, on Behalf of the United States and the State of Iowa, et al.

Paid petition · United States Court of Appeals for the Eighth Circuit, No. 22-3481, 22-3591 · judgment July 8, 2024


Certiorari denied · June 23, 2025
Pre-decision estimate: 4% cert probability

Before the decision, roughly the 4.1% base rate. The model weighted this up for counsel who has won certiorari before and an Eighth Circuit decision below.

Question presented

The public disclosure bar of the False Claims Act (FCA), 31 U.S.C. § 3729 et seq., forecloses a qui tam FCA action or claim if “substantially the same allegations or transactions as alleged in the action or claim were publicly disclosed.” 31 U.S.C. § 3730(e)(4)(A). Ten circuits—the First, Second, Third, Fourth, Fifth, Sixth, Ninth, Tenth, Eleventh, and D.C. Circuits—apply the statute as written and hold that the public disclosure bar is triggered if the disclosure identifies substantially the same transactions as the ones at issue in the FCA suit. But two circuits—the Seventh and Eighth Circuits—require the disclosure to additionally contain an express allegation of fraud. The question presented is: Whether the public disclosure bar requires an express allegation of fraud. (i)

Counsel of record

For petitioner
Jessica Lynn Ellsworth
Hogan Lovells US, LLP

For respondent
D. John Sauer
Solicitor General

Case

Conference history
Distributed for 2 conferences

Related
Vide, 24-549

Linked docket
24A594

Proceedings

  1. Jun 23 2025
    Petition DENIED.
  2. Jun 03 2025
    DISTRIBUTED for Conference of 6/18/2025.
  3. Jun 02 2025
    Reply of petitioners Steven Zorn, et al. filed. (Distributed)
  4. May 16 2025
    Brief of respondent Stephen B. Grant in opposition filed.
  5. Apr 30 2025
    Response Requested. (Due May 30, 2025)
  6. Apr 29 2025
    DISTRIBUTED for Conference of 5/15/2025.
  7. Apr 15 2025
    Waiver of the 14-day waiting period for the distribution of the petition pursuant to Rule 15.5 filed by petitioner.
  8. Apr 11 2025
    Brief of respondent United States in opposition filed. VIDED.
  9. Apr 08 2025
    Motion to extend the time to file a response is granted and the time is further extended to and including April 11, 2025.
  10. Apr 07 2025
    Motion to extend the time to file a response from April 9, 2025 to April 11, 2025, submitted to The Clerk.
  11. Mar 05 2025
    Motion to extend the time to file a response is granted and the time is extended to and including April 9, 2025.
  12. Mar 04 2025
    Motion to extend the time to file a response from March 10, 2025 to April 9, 2025, submitted to The Clerk.
  13. Mar 03 2025
    Waiver of right of respondent Stephen B. Grant to respond filed.
  14. Feb 05 2025
    Petition for a writ of certiorari filed. (Response due March 10, 2025)
  15. Dec 18 2024
    Application (24A594) granted by Justice Kavanaugh extending the time to file until February 6, 2025.
  16. Dec 13 2024
    Application (24A594) to extend the time to file a petition for a writ of certiorari from January 7, 2025 to February 6, 2025, submitted to Justice Kavanaugh.