3729. d. Post -Stevens FCA Jurisprudence The Supreme Court’s opinion in Stevens did not squarely resolve the question before this Court: whether municipalities and their agencies are immune from suit under the FCA. The federal courts addressing this issue have split once again. The majority of courts have concluded that municipalities, like states, are immune from FCA claims brought by qui tam relators. See, e.g., United States ex rel. Garibaldi v. Orleans Parish Sch. Bd., 244 F.3d 486, 495 (5th Cir.2001) (“The punitive damage regime of the False Claims Act shows a congressional intent that the False Claims Act should not be applied to local governments.”); United States ex rel. Honeywell v. San Francisco Housing Auth., No. C99-1936 TEH, 2001 WL 793300, at *4 (N.D.Cal. July 12, 2001) (<HOLDING>); United States ex rel. Chandler v. Hektoen
holding that an action naming a state entity as a defendant did not constitute an action against the state because the state entity was sued in its capacity as receiver holding that a special relaxing of rule 9b is a qui tam plaintiffs ticket to the discovery process that the statute itself does not contemplate holding that rule 9b applies to fca holding that discrimination against a municipal employee could trigger municipal liability under  1983 through official policy or custom holding that plaintiff could not maintain a qui tam fca action against a municipal entity