United States ex. rel. Bledsoe v. Community Health System, Inc.,
No. 2:00-0083 (M.D. Tenn. Sept. 18, 2001)

The U.S. District Court for the Middle District of Tennessee held that a Relator's amended complaint alleging False Claims Act violations by defendants failed to satisfy the requirement of pleading fraud with particularity under the Federal Rules of Civil Procedure, and that the Relator similarly failed to state a valid "action" under the False Claims Act. The Relator's complaint failed to meet the pleading requirements under the Federal Rules because he did not identify any specific physicians who referred patients for medically unnecessary services or any specific claims for medically unnecessary services, nor did he state a time period during which the alleged unlawful acts took place.