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Neutral Court Opinion Apr 18, 2026

U.S. ex rel. Matt Anderson v. St. Elizabeth Med. Ctr.

── U.S. ex rel. Matt Anderson v. St. Elizabeth Med. Ctr. ── Court: Court of Appeals for the Sixth Circuit Date: April 17, 2026 Category: General NOT RECOMMENDED FOR PUBLICATION File Name: 26a0174n.06 Case No. 25-5858 UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT FILED Apr 17, 2026 ) KELLY L. STEPHENS, Clerk UNITED STATES OF AMERICA and ) COMMONWEALTH OF KENTUCKY ex rel., ) MATT ANDERSON. ) ON APPEAL FROM THE ________________________________________ ) UNITED STATES DISTRICT UNITED STATES OF AMERICA, ) COURT FOR THE EASTERN Intervenor-Plaintiff, ) DISTRICT OF KENTUCKY ) MATT ANDERSON, ) ) OPINION Relator-Appellant, ) ) v. ) ) SAINT ELIZABETH MEDICAL CENTER, INC.; ) SUMMIT MEDICAL GROUP, INC., dba St. ) Elizabeth Physicians, ) Defendants-Appellees. ) Before: CLAY, McKEAGUE, and NALBANDIAN, Circuit Judges. NALBANDIAN, Circuit Judge. Matt Anderson believes that St. Elizabeth Medical Center, Inc., and Summit Medical Group, Inc. (together, St. Elizabeth) hoodwinked state and federal public healthcare programs by charging them for medically unnecessary kidney and vascular procedures and receiving kickbacks. So Anderson sued St. Elizabeth under the False Claims Act (FCA), 31 U.S.C. § 3729 et seq., and Kentucky’s negligence per se statute, Ky. Rev. Stat. § 446.070. The district court granted St. Elizabeth’s motion for judgment on the pleadings, reasoning that Anderson’s FCA claim is barred because his allegations were already in the public domain and that the Kentucky law claim fails as a matter of law. We largely agree, and to the No. 25-5858, U.S. ex rel. Anderson v. St. Elizabeth Med. Ctr., et al. extent we don’t, we find that Anderson’s claims fail for independent reasons supported by the record. So we affirm. I. This is a case about doctors allegedly defrauding the government. More specifically, it’s about the standards by which the law decides whether a whistleblower can sue on such allegations in the government’s place. We’ve got three questions to answer on that front. How much fresh information does the FCA—the federal statute empowering private individuals to bring such claims on behalf of the government—require before assigning the whistleblower the right to sue? How specific must the whistleblower’s factual allegations of fraud be to pass muster under the Federal Rules of Civil Procedure? And does Kentucky law offer a device of its own to empower private plaintiffs to initiate civil suits on the government’s behalf? To answer those questions, we start by recounting the story that prompted us to ask them in the first place. That tale began more than seven years before this lawsuit, in a since-dismissed case called United States ex rel. Kent v. St. Elizabeth Medical Center (Kent), 2:17-cv-3 (E.D. Ky. Jan. 11, 2017). So we’ll begin there, then move to the facts and procedural history underlying this appeal.
CourtListener · Apr 17, 2026
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