State Farm Shows RICO Settlement Covers Whistleblower Claims

State Farm Mutual Automobile Insurance Co. convinced the Sixth Circuit that the company’s settlement of a Racketeer Influenced and Corrupt Organizations Act lawsuit against a Michigan pharmacy owner also required dismissal of his False Claims Act suit against the insurer.

State Farm sued Michael Angelo in March 2019 alleging that he submitted fraudulent bills—in violation of RICO—by engaging in a scheme to prescribe unnecessary opioids to people involved in car accidents. The parties reached a settlement in February 2021.

In July 2019, while the RICO action was pending, Angelo brought an FCA action alleging that State Farm exploited Michigan’s automobile ...