Vermont Agency of Natural Resources v. United States ex rel. Stevens, 529 U.S. 765, 37 (2000)

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

Stevens, J., dissenting

payers and citizens for whose benefit the wrongdoer was being chastised." 453 U. S., at 263. That rationale is inapplicable here. The taxpaying "citizens for whose benefit" the FCA is designed are the citizens of the United States, not the citizens of any individual State that might violate the Act. It is true, of course, that the taxpayers of a State that violates the FCA will ultimately bear the burden of paying the treble damages. It is not the coffers of the State (and hence state taxpayers), however, that the FCA is designed to protect, but the coffers of the National Government (and hence the federal taxpayers). Accordingly, a treble damages remedy against a State does not "burden the very taxpayers" the statute was designed to protect.11

III

Each of the constitutional issues identified in the Court's opinion requires only a brief comment. The historical evidence summarized by the Court, ante, at 774-778, is obviously sufficient to demonstrate that qui tam actions are "cases" or "controversies" within the meaning of Article III. That evidence, together with the evidence that private prosecutions were commonplace in the 19th century, see Steel Co. v. Citizens for Better Environment, 523 U. S. 83, 127-128, and nn. 24-25 (1998) (Stevens, J., concurring in judgment), is also sufficient to resolve the Article II question that the Court has introduced sua sponte, ante, at 778, n. 8.

As for the State's "Eleventh Amendment" sovereign immunity defense, I adhere to the view that Seminole Tribe of Fla. v. Florida, 517 U. S. 44 (1996), was wrongly decided. See Kimel v. Florida Bd. of Regents, 528 U. S. 62, 97-99 (2000) (Stevens, J., dissenting); Seminole Tribe, 517 U. S., at 100-185 (Souter, J., dissenting). Accordingly, Congress' clear intention to subject States to qui tam actions is also

11 It is also worth mentioning that treble damages may be reduced to double damages if the court makes the requisite findings under §§ 3729(a)(7)(A)-(C).

801

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