In the case of Graham County Soil & Water Conservation District, et al. v. United States ex rel. Karen T. Wilson (2004), whistleblower Karen Wilson alleged that Graham County Soil and Water Conservation District had submitted false claims to the federal government in violation of the False Claims Act (FCA). The Supreme Court was asked to determine whether a state or local legislative report could be considered a "public disclosure" under FCA, which would bar individuals from bringing suit based on information contained within such reports unless they were an original source of the information. In a unanimous decision, it held that public disclosures can include state and local administrative reports as well as federal ones; therefore barring suits not brought by an original source based on these documents' contents.

In the dissenting opinion for Graham County Soil & Water Conservation District v. United States ex rel. Karen T. Wilson, it was argued that the majority's interpretation of the False Claims Act (FCA) was too narrow and inconsistent with Congress' intent to encourage private enforcement actions against fraud on federal programs, regardless of whether they are administered by state or local entities. The dissent pointed out that this restrictive reading could potentially shield fraudulent activities from liability if they were carried out through a non-federal entity using federal funds, which would undermine the purpose of FCA as a tool to combat fraud against government programs funded by taxpayers' money.