Vermont Agency of Natural Resources v. United States ex rel. Stevens, 529 U.S. 765, 35 (2000)

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Cite as: 529 U. S. 765 (2000)

Stevens, J., dissenting

clude any definition of "person" at all. The negative inference drawn by the Court, if taken seriously, would therefore prove too much. The definition of "person" in § 3733 includes not only States, but also "any natural person, partnership, corporation, association, or other legal entity." § 3733(l)(4). If the premise of the Court's argument were correct—that the inclusion of certain items as a "person" in § 3733 implies their exclusion as a "person" in § 3729—then there would be absolutely no one left to be a "person" under § 3729.9 It is far more reasonable to assume that Congress simply saw no need to add a definition of "person" in § 3729 because (as both the legislative history, see supra, at 791- 795, and the definitions in the CID provisions demonstrate) the meaning of the term "person" was already well understood. Congress likely thought it unnecessary to include a definition in § 3729 itself.

The Court also relies on the definition of "person" in a separate, but similar, statute, the Program Fraud Civil Remedies Act of 1986 (PFCRA). Ante, at 786. The definition of "person" found in that law includes "any individual, partnership, corporation, association, or private organization." 31 U. S. C. § 3801(a)(6). It is first worth pointing out the obvious: Although the PFCRA sits next to the FCA in the United States Code, they are separate statutes. It is therefore not altogether clear why the former has much bearing on the latter.10 Regardless, the Court's whole argument

9 Not so, the Court says, because natural persons and other entities, unlike States, are presumed to be included within the term "person." Ante, at 784, n. 14. In other words, this supposedly independent textual argument does nothing on its own without relying entirely on the presumption already discussed. See supra, at 797-798; ante, at 780- 784. The negative inference adds nothing on its own.

10 Indeed, reliance on the PFCRA seems to contradict the Court's central premise—that in 1863 the word "person" did not include States and that scattered intervening amendments have done nothing to change that. Ante, at 781-782. If that were so, the relevant meaning of the word

799

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