Lestage v. Coloplast Corp., No. 19-2037 (1st Cir. 2020)
Annotate this Case
In this case brought under the anti-retaliation provision of the False Claims Act, the First Circuit affirmed the judgment of the district court awarding Plaintiff $762,525 in compensatory damages, holding that the causation standard for retaliation claims under the Act is a "but-for" standard.
Plaintiff filed suit against Defendant, her employer, alleging that Defendant had retaliated against her in violation of the Act after it learned that she had filed a qui tam action against it and one of its largest customers. The jury awarded Plaintiff compensatory damages, and the district court denied Plaintiff's subsequent motions for judgment as a matter of law and a new trial. The First Circuit affirmed, holding (1) retaliation claims under the Act must be evaluated under the "but-for" causation standard; (2) the "substantial motivating factor" instruction given to the jury was erroneous, but the instruction was not plain error; (3) the jury supportably found sufficient evidence against Defendant on the retaliation claim; and (4) the district court properly denied Defendant's motion for a new trial.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.