DISCLAIMER: The following unofficial case summaries are prepared by the clerk's office
as a courtesy to the reader. They are not part of the opinion of the court.
163783P.pdf 08/01/2017 United States ex rel Fields v. Bi-State Development Agency
U.S. Court of Appeals Case No: 16-3783
U.S. District Court for the Eastern District of Missouri - St. Louis
[PUBLISHED] [Kelly, Author, with Gruender and Murphy, Circuit Judges]
Civil case - False Claims Act. For the court's prior opinion in the
matter, see United States ex rel Fields v. Bi-State Dev. Agency of the
Mo.-Ill Dist., 829 F.3d 598 (8th Cir. 2016. The district court did not err
in finding defendant Bi-State is akin to a local government entity and not
entitled to Eleventh Amendment immunity; the factors used in making the
"arm-of-the-state" analysis point in both directions; in such a situation,
the prime guide for making the determination must be the twin reasons
underlying the Amendment - respect for the dignity of the states as
sovereigns and prevention of federal court judgments that must be paid out
of a State's treasury; applying these reasons it is clear that a suit
against Bi-State does not present the same kind of sovereignty issues
involved in a suit against a state and that any federal judgment would not
be paid with state funds; as a result, the district court properly found
Bi-State was not entitled to Eleventh Amendment immunity.