Armstrong v. The Arcanum Group, No. 17-1378 (10th Cir. 2018)Annotate this Case
Mindy Armstrong was employed by The Arcanum Group, Inc., which served as a placement agency to staff federal-government positions. She was placed with the Real Estate Leasing Services Department of the Bureau of Land Management (BLM). After she complained that BLM employees were falsifying lease-related records, the BLM demanded that Arcanum remove her from the placement. Her Arcanum supervisor could not find an alternative placement for Armstrong and accordingly terminated her employment. Armstrong sued Arcanum in federal district court, claiming Arcanum retaliated against her for her falsification complaints, in violation of the antiretaliation provisions of the False Claims Act (FCA) and the National Defense Authorization Act (NDAA). The district court granted Arcanum summary judgment, and Armstrong appealed. Finding that Armstrong did not produce sufficient evidence that her supervisor had knowledge of her complaints before he terminated her, the Tenth Circuit Court of Appeals affirmed summary judgment in favor of the employer.