Sprague v. Office of the Chief Medical Examiner
- Katherine Failla
- 1:25-cv-05671
- U.S. District Court · Southern District of New York
- 2
In Sprague v. Office of the Chief Medical Examiner, Judge Failla found no False Claims Act basis for sealing the complaint and ordered it opened publicly.
Ethan Sprague, the defendants named in the complaint, and members of the public who can now access the action on the public docket.
What happened
In Sprague v. Office of the Chief Medical Examiner, Ethan Sprague sued over his mother’s alleged wrongful death and filed the complaint under seal. He marked the False Claims Act on the civil cover sheet and wrote “Concealment & Fraud (??).”
The court reviewed the complaint to determine whether the False Claims Act justified keeping it sealed. The court found that the alleged facts did not fall within that law and did not state a False Claims Act claim.
The court therefore ordered the Clerk of Court to open the case on the public docket. The order was signed by Judge Katherine Polk Failla.
The detailed version
- Sprague v. Office of the Chief Medical Examiner · No. 1:25-cv-05671
- Katherine Failla
- July 25, 2025
Background
Ethan Sprague, representing himself, brought an action asserting claims for the wrongful death of his mother. On the civil cover sheet, he selected the False Claims Act, a federal law imposing civil liability for certain knowing false claims made to the federal government. He also wrote “Concealment & Fraud (??).”
The complaint was filed under seal. The False Claims Act generally requires a proper private enforcement action brought for the United States to be filed under seal while the government has an opportunity to investigate. The court conducted a preliminary review of the complaint.
Court’s Analysis
The court found that the facts alleged did not fall within the False Claims Act and that the complaint did not state a claim under that law. As a result, the court found no statutory basis for keeping the complaint sealed.
Disposition
The court directed the Clerk of Court to open the action on the public docket. The order addressed whether the complaint could remain sealed based on the False Claims Act; the text does not state that the court resolved the wrongful-death claims on their merits. Judge Katherine Polk Failla signed the order.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.