examined the language of the pre-1986 federal statute and several conflicting Supreme Court decisions to find that a “claim” under that version of the statute meant a demand for money or property, so that the statute did not include “reverse false claims.” Id. at 10 (finding that fraudulent applications for charity status made to the Postal Service did not constitute “claims” within the meaning of the pre-1986 act despite the fact that the claims led to the underpayment of the Postal Service). See also Rabushka ex rel. United States v. Crane Co., 122 F.3d 559, 565 n. 8 (8th Cir.1997) (noting that every circuit considering whether reverse false claims could be sustained under the pre-1986 act rejected that proposition); United States v. Howell, 318 F.2d 162, 165-66 (9th Cir.1963) (<HOLDING>). But see United States v. Douglas, 626 F.Supp.
holding that apparel cleaners submission of false statements of their receipts a percentage of which were to be paid to the united states did not constitute false claims within the meaning of the federal false claims act holding that a state agency is not a person subject to suit under federal false claims act holding implied false certifications must be material to the governments payment decision in order to be actionable under the false claims act holding that false arrest and false imprisonment claim were not duplicative holding that the provisions of the false claims act allowing suit imposing liability on any person who presented false claims to the federal government did not allow suits against state governments