Darrell Prince, proceeding pro se, appealed a district court order that dismissed his complaint. Prince had filed a qui tam action, a type of lawsuit that allows private individuals to sue on behalf of the government for fraud against the United States. The district court dismissed the complaint, concluding that Prince lacked the legal authority to bring such an action. Prince filed various ancillary motions, including requests to supplement the appellate record and for a temporary restraining order, which were also addressed by the appellate court.
The D.C. Circuit reviewed the appeal on the record and briefs. The court held that the district court correctly concluded that private litigants may not file qui tam complaints on behalf of the United States. The court relied on the precedent set in Jones v. Jindal, 409 Fed. App'x 356 at *1 (D.C. Cir. 2011), which establishes that private individuals do not have standing to bring such actions. Regarding the procedural motions, the court found that the record on appeal already included the original papers and exhibits from the district court as required by Federal Rule of Appellate Procedure 10(a)(1). Consequently, the court denied the motion to supplement the record insofar as it sought further additions, noting that Prince failed to show that such relief was warranted. The court also denied the remainder of the appellant's motions, stating he had not shown entitlement to the requested relief.
The dismissal of Prince's qui tam complaint stands, reinforcing the limitation that private citizens cannot initiate false claims actions on the government's behalf. The decision clarifies that the appellate record is generally limited to the original district court filings, preventing parties from introducing new materials on appeal without specific justification. The mandate was withheld for seven days to allow for any potential petitions for rehearing.
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