United States ex rel. Schutte v. Supervalu Inc.
View Official PDFSummary
A short, plain-English overview of United States ex rel. Schutte v. Supervalu Inc..
In United States ex rel. Schutte v. Supervalu Inc., the Supreme Court addressed whether retail pharmacies knowingly submitted false claims under the False Claims Act by reporting higher retail prices instead of discounted prices to federal benefits programs. The District Court found the claims false but ruled the pharmacies did not act knowingly. The Seventh Circuit affirmed, but the Supreme Court vacated and remanded, focusing on the defendant's subjective beliefs rather than an objectively reasonable interpretation.
Holding
The single most important “bottom line” of what the Court decided in United States ex rel. Schutte v. Supervalu Inc..
The Court held that the FCA's scienter element refers to a defendant's knowledge and subjective beliefs, not an objectively reasonable person's understanding.
Key Quotes
Short excerpts from the syllabus in United States ex rel. Schutte v. Supervalu Inc. that support the summary and concepts above.
The FCA's scienter element refers to a defendant's knowledge and subjective beliefs.
Actual knowledge, deliberate ignorance, or recklessness will suffice.
The focus is on what a defendant thought when submitting a claim.
