威斯康星贝尔公司诉美国前 Relator Heath 案

Wisconsin Bell, Inc. v. United States ex rel. Heath is a 2025 U.S. Supreme Court case regarding the False Claims Act (FCA). Auditor Todd Heath alleged that Wisconsin Bell defrauded the FCC's E-Rate program by overcharging schools in violation of the "lowest corresponding price" rule, leading to inflated reimbursements. Wisconsin Bell moved to dismiss, arguing E-Rate reimbursement requests do not qualify as FCA "claims" because the funds come from private carriers, not the government. The Supreme Court unanimously held that these requests are "claims" under the FCA because the government provided a portion of the funds—over $100 million from the U.S. Treasury. Justice Kagan delivered the opinion.

The Supreme Court unanimously affirmed the Seventh Circuit's judgment, holding that E-Rate reimbursement requests qualify as "claims" under the FCA because the government provided over $100 million from the U.S. Treasury into the Fund. The case was remanded to the District Court for further proceedings. Justice Kagan authored the unanimous opinion, with Justices Thomas and Kavanaugh filing concurrences.

Whether reimbursement requests submitted to the E-Rate program constitute "claims" under the False Claims Act when the government does not directly pay the funds but rather the money comes from private carriers and is administered by a private corporation. The central issue was whether the government "provides or has provided any portion of the money" requested, as required by the FCA's definition of "claim".

The decision ensures that the False Claims Act can be used to combat fraud in public-private programs like E-Rate, protecting federal interests even when funds pass through private hands. It settled a circuit split regarding the scope of FCA liability in such programs. However, the Court's narrow reasoning—focusing solely on the government's direct monetary contribution—may limit its applicability to other programs lacking similar federal funding.