United States ex rel. Szymczak v. Covenant Healthcare Sys., 2006 U.S. App. LEXIS 32112 (7th Cir. 2006)

James Szymczak brought a qui tam action against a hospital and nursing home alleging that fraudulent Medicare claims were filed and payment was received for unnecessary, unrendered, misrepresented, and unreimbursable services in violation of the False claims act (31 USC § 3729-31). Szymczak filed the action pro se and the district court dismissed the action, based on the holding in U.S. ex rel Lu v. Ou, 368 F.3d 773, 775 (7th Cir. 2004), which held that a pro se relator cannot prosecute a qui tam action. The decision was affirmed.