United States ex rel Fields v. Bi-State Development Agency, No. 16-3783 (8th Cir. 2017)
Annotate this CaseThe Eighth Circuit affirmed the district court's denial of summary judgment to Bi-State in a False Claims Act (FCA), action brought by a private actor. Bi-State is an interstate compact entity that owns and operates public transportation services. After determining that the Barket factors point in two different directions, the court turned to the "Eleventh Amendment's twin reasons for being" as its "prime guide" in determining whether Bi-State was more like an arm of the state or a local government entity. In this case, the twin reasons for being, respect for the dignity of the states as sovereigns and the prevention of federal-court judgments that must be paid out of a State's treasury, weigh in favor of finding that Bi-State was more like a local government entity. Therefore, Bi-State does not enjoy the special constitutional protection of the States themselves and was not entitled to Eleventh Amendment sovereign immunity.
Court Description: Kelly, Author, with Gruender and Murphy, Circuit Judges] Civil case - False Claims Act. For the court's prior opinion in the matter, see United States ex rel Fields v. Bi-State Dev. Agency of the Mo.-Ill Dist., 829 F.3d 598 (8th Cir. 2016. The district court did not err in finding defendant Bi-State is akin to a local government entity and not entitled to Eleventh Amendment immunity; the factors used in making the "arm-of-the-state" analysis point in both directions; in such a situation, the prime guide for making the determination must be the twin reasons underlying the Amendment - respect for the dignity of the states as sovereigns and prevention of federal court judgments that must be paid out of a State's treasury; applying these reasons it is clear that a suit against Bi-State does not present the same kind of sovereignty issues involved in a suit against a state and that any federal judgment would not be paid with state funds; as a result, the district court properly found Bi-State was not entitled to Eleventh Amendment immunity.
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