Michael P. Moore v. California Institute of Technology Jet Propulsion Laboratory

Plaintiff-Appellant Michael P. Moore (“Moore”) appeals the district court’s grant of summary judgment in favor of his former employer, Defendant-Appellee California Institute of Technology Jet Propulsion Laboratory (“JPL”), regarding Moore’s retaliation claims against JPL under the False Claims Act, 31 U.S.C. § 3730 (h), and the Major Fraud Act, 18 U.S.C. § 1031 (h). Moore, who specialized in large antenna mechanics, told the National Aeronautics and Space Administration (“NASA”) Inspector General that he suspected fraud at JPL involving a large antenna JPL was building for NASA Af-terwards, JPL made several proposals to Moore concerning his work with JPL that he alleges were retaliatory. For example, JPL proposed that Moore transfer to another group without being able to take with him the projects he had been working on. JPL also proposed to eliminate Moore’s job title and put him under an intermediate supervisor. Because Moore protested, none of these proposals were implemented. The District Court held that these proposals did not amount to retaliation, because they were not “clearly unreasonable, such that an objective observer would understand that the proposal was nothing…