On October 11, 2016, a three-judge panel of the Seventh Circuit
Court of Appeals issued a ruling in United States ex rel. Uhlig
v. Fluor Corp., affirming summary judgment against the relator
in an FCA action where the government had declined to intervene.
See generally 2016 WL 5905714, No. 14-2815 (7th Cir. Oct.
11, 2016).
The defendant had contracted with the US Army to perform
electrical work at bases in Northern Afghanistan. It hired the
relator, an electrician, as a foreperson for this work, but
subsequently declined to renew his contract because he did not hold
an electrician's license. The relator then emailed the Defense
Contract Management Agency, complaining that he was losing his job
while other unlicensed electricians, who were Afghan nationals,
were not. In a follow-up email, the relator alleged that the
defendant company was committing fraud, and copied a website
dedicated to "exposing . . . corporate greed among [defense]
contractors." The company then
