Schindler Elevator Corp. v. United States ex rel. Kirk

Summary

The Court held that a federal agency's written response to a FOIA request constitutes a "report" within the meaning of the False Claims Act's public disclosure bar. It reversed the Second Circuit, which had held such responses were not reports, because the ordinary meaning of "report" includes something that gives information. Justice Ginsburg dissented, arguing that such ministerial responses should not bar qui tam suits.