No. 25-893

Robert V. Smith v. Jay A. Odom, et al.

Lower Court: Eleventh Circuit
Docketed: 2026-01-29
Status: Pending
Type: Paid
Tags: false-claims-act fraud-prevention original-source public-disclosure statutory-interpretation whistleblower
Latest Conference: N/A
Question Presented (from Petition)

Whether the requirement in 31 U.S.C. § 3730(e)(4)(B) that a relator have "knowledge that is independent of and materially adds to the publicly disclosed allegations or transactions" requires a distinct inquiry into whether the relator's non-public information meaningfully contributes to the government's understanding or ability to act on the publicly disclosed information, as applied by a majority of circuits, or whether overlap with public disclosures bars the action, as applied by other circuits?

Question Presented (AI Summary)

Whether the requirement in 31 U.S.C. § 3730 (e)(4)(B) that a relator have 'knowledge that is independent of and materially adds to the publicly disclosed allegations or transactions' requires a distinct inquiry into whether the relator's non-public information meaningfully contributes to the government's understanding or ability to act on the publicly disclosed information, as applied by a majority of circuits, or whether overlap with public disclosures bars the action, as applied by other circuits?

Docket Entries

2026-03-02
Brief of Okaloosa County, Board of County Commissioners in opposition submitted.
2026-02-27
Brief of Jay A. Odom in opposition submitted.
2026-01-17
Petition for a writ of certiorari filed. (Response due March 2, 2026)

Attorneys

Jay A. Odom
Barry Scott RichardBarry Richard Law Firm, Respondent
Okaloosa County, Board of County Commissioners
Gregory Thomas StewartNabors, Giblin, Nickerson, Respondent
United States of America and the State of Florida Ex Rel. Robert V. Smith
William Kelly PulsPuls & Liebrecht, P.C., Petitioner