Alaska Employment Law

The panel’s introduction says it all: 

Marie Bernadette Mendiondo appeals from the district court’s order dismissing her complaint. Mendiondo worked as a nurse at Centinela Hospital Medical Center (”CHMC”) and alleged that, following her complaints regarding false billing and reimbursement practices and substandard patient care, she was wrongfully terminated in violation of the Federal False Claims Act (”FCA”) (31 U.S.C. § 3730(h)), the California False Claims Act (”CFCA”) (California Government Code § 12653(b)), California Health and Safety Code § 1278.5, and the public policies embodied by these laws.

This appeal requires that we decide whether a claim for wrongful termination under the FCA and CFCA, brought in federal court, must meet the notice pleading standard in Federal Rule of Civil Procedure 8(a) or the heightened pleading standard in Rule 9(b). We hold that the Rule 8(a) standard applies. Because Mendiondo’s complaint, though inartfully drafted, meets the Rule 8(a) notice pleading standard with respect to all of her claims, we reverse and remand.

Mendiondo v. Centinela Hosp. Med. Ctr., 20078 WL 852186 (9th Cir. Apr. 1, 2008)