P. ex rel. Limpin v. Newsom CA4/1

I. INTRODUCTION

The California False Claims Act (CFCA) allows a private citizen to bring a lawsuit on behalf of “the State of California . . . if any state funds are

involved” in a fraudulent use. (Gov. Code,1 § 12650 et seq.) These are referred to as qui tam actions. Melchor Karl T. Limpin brought a CFCA suit based on legislation allowing certain benefits to non-United States citizens residing in California. The State of California successfully moved the trial court to dismiss Limpin’s qui tam suit. Limpin appeals from that ruling, challenging all three grounds

on which the dismissal order relied:2 Because we conclude the trial court properly decided the state showed it had good cause to support dismissal, we need not reach the other grounds asserted. Finally, Limpin argues the trial court improperly used a local rule to avoid addressing the substance of his request to join the Attorney General as a necessary party. He is incorrect because the trial court also denied the joinder request on the merits. Accordingly, we affirm.

II. BACKGROUND

Limpin filed his qui tam action in 2023. In his first amended complaint (FAC), Limpin named as defendants Governor Gavin Newsom, State…