per claim; the current version, by contrast, generally imposes treble damages and a civil penalty of up to $10,000 per claim. The very idea of treble damages reveals an intent to punish past, and to deter future, unlawful conduct, not to ameliorate the liability of wrongdoers. Id. at 785, 120 S.Ct. 1858 (internal citations and quotations omitted). Thus, given the presumption against imposing punitive damages on governmental entities, and the absence of any evidence suggesting a contrary congressional intent, the Court concluded that a state could not be sued under sect t. for Med. Research, 118 F.Supp.2d 902, 903 (N.D.Ill.2000) (“[Cook] County is immune from prosecution under the FCA because it is immune from any award or claim for punitive damages.”); Dunleavy, 2000 WL 1522854, at *8 (<HOLDING>). In reaching this conclusion, these courts
holding that county of delaware was not a person for purposes of fca liability holding that county defendant was a person within meaning of fca for purposes of suit by private plaintiff holding that subsection c2 of the delaware longarm statute requires that service contracts must be for services performed in delaware holding that a county is not an arm of the state for purposes of the eleventh amendment holding before the apa definition of person was amended to include county that the board of county commission ers of dolores county could not sue the state agency that had ordered reappraisals of real property in dolores county in connection with valuation for ad valorem taxation because the board of county commissioners was not a person under the apa and did not otherwise have authority to sue under statute or constitution