Opinion
Civil Action No. 17-1804 (UNA)
01-02-2018
MARVIN WATSON, JR., Plaintiff, v. SCOTT P. BONHAM, et al., Defendants.
MEMORANDUM OPINION
Plaintiff purports to bring a claim under the False Claims Act, which generally establishes liability for one who "knowingly presents, or causes to be presented, a false or fraudulent claim for payment or approval" to the United States or one of its employees or contractors. 31 U.S.C. § 3729(a)(1)(A). A pro se party, however, may not file such an action. See Idrogo v. Castro, 672 F. App'x 27 (D.C. Cir. Sept. 30, 2016) (per curiam) ("The district court correctly held that pro se plaintiffs, such as appellant, may not file a qui tam action pursuant to the False Claims Act[.]"); U.S. ex rel. Fisher v. Network Software Asssocs., 377 F. Supp. 2d 195, 197 (D.D.C. 2005) ("The Court therefore holds that plaintiff may not maintain this suit as a qui tarn relator without the assistance of counsel."). In an action under the False Claims Act, "the real party in interest . . . is the United States," U.S. ex rel. Fisher, 377 F. Supp. 2d at 196 (citation omitted), and a pro se "plaintiff is not qualified as a lay person to represent the interests of the United States in court proceedings," Rockefeller v. Westinghouse Elec. Co., 274 F. Supp. 2d 10, 16 (D.D.C. 2003).
This matter is before the Court on plaintiff's application to proceed in forma pauperis and his pro se complaint. The Court will grant the application and dismiss the complaint without prejudice.
An Order accompanies this Memorandum Opinion. DATE: January 2, 2018
/s/_________
United States District Judge