In the case of Cook County, Illinois v. United States ex rel. Janet Chandler in 2002, the U.S Supreme Court ruled that local governments are not considered "persons" under the False Claims Act (FCA). The FCA allows private individuals to file lawsuits on behalf of the federal government against entities who have defrauded it and receive a portion of any recovered damages. Janet Chandler had filed such a suit against her employer, Cook County Hospital, alleging fraudulent billing practices. However, because municipalities cannot be classified as "persons," they cannot be sued under this act according to its original language from 1863 or its amendments in 1986. Therefore, Chandler's lawsuit was dismissed by the court.

In the dissenting opinion for Cook County, Illinois v. United States ex rel. Janet Chandler, Justice Scalia disagreed with the majority's interpretation of the False Claims Act (FCA). He argued that a county hospital should not be considered a "person" under this act and thus could not be sued for fraud against itself. According to him, it was illogical to think that Congress intended local governments to sue themselves when they passed this law in 1863 during the Civil War era as there were no instances of such suits at that time. Furthermore, he pointed out inconsistencies in how different types of government entities are treated under FCA; federal agencies cannot be sued while local ones can which is contradictory and unfair according to him. Lastly, he criticized the majority's reliance on legislative history instead of clear statutory text leading them towards an erroneous conclusion.