Rigsby places discretion in the hands of district courts as to whether and how to sanction relators who violate the seal requirement in False Claims Act cases.

On December 6, 2016, only a month after oral argument, the U.S. Supreme Court issued a unanimous decision in State Farm Fire & Casualty Co. v. United States ex rel. Rigsby, No. 15-513 (Kennedy, J.). The Court rejected petitioner State Farm’s contention that a relator’s violation of the seal requirement in federal False Claims Act (FCA) cases requires a mandatory dismissal of the action. However, the Court held that dismissal may be appropriate in some cases. The Court refused to adopt a specific standard to be applied but tacitly endorsed the Ninth Circuit’s three-factor balancing test to determine the proper sanction to address a seal violation.