City of San Diego v. Means
City of San Diego (the City) appeals a summary judgment in favor of Tracy L. Means, a former deputy director who managed the City's two airports, on its complaint against her for violating the City's rules and regulations pertaining to competitive bidding and the letting of contracts for consultant services. Court reverse the judgment insofar as it concerns the two causes of action under California's False Claims Act (FCA) (Gov. Code, 12650 et seq.), as there are triable issues of material fact concerning whether Means "knowingly" presented false claims to the City within the meaning of the FCA. In all other respects we affirm the judgment. As a matter of law, Means is immune under Government Code section 822.2 from liability for common law misrepresentation, and California's unfair competition law (UCL) (Bus. & Prof. Code, 17200 et seq.) and section 108 of the City's Charter are inapplicable.
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