Improper Substitution of Parties Constitutes Violation of FCA’s First-to-File Rule; U.S. Court of Appeals for the Tenth Circuit No. 16-4152, United States ex rel. Donald Little and Kurosh Motaghed v. Triumph Gear Systems Inc.

The Tenth Circuit reversed a district court ruling and dismissed a False Claims Act suit against Triumph Gear Systems Inc., finding that the original relator’s attorney had improperly substituted himself and another individual for the original complainant and thereby violated the FCA’s first-to-file rule.