Bly-Magee

In 2001 Charlotte Bly-Magee filed this qui tam action under the False Claims Act, 31 U.S.C. § 3729 . She accuses the California Department of Rehabilitation (“CDR”) and its employees of defrauding the federal government. The district court dismissed her Second Amended Complaint, without leave to amend. The district court held that Bly-Magee had failed to overcome the False Claims Act’s jurisdictional bar that precludes private actions based on public disclosure of allegations unless the relator who is bringing the action is an original source of the information. See 31 U.S.C. § 3730 (e)(4)(A). Bly-Magee now appeals.

Background

For over a decade, Bly-Magee has been pursuing qui tam actions against CDR. She initially suspected CDR of filing false claims while she was serving as the execu tive director of Southern California Rehabilitation Services, a non-profit organization that receives federal and state funds to serve the disabled. Shortly after leaving Southern California Rehabilitation Services, she filed the first of three qui tam actions (“Bly-Magee I”). The government declined to intervene in this action. A district court granted summary judgment against Bly-Magee, and she…