In United States ex rel. Holmes v. Northrop Grumman Corp., a Mississippi federal district court disqualified an attorney whistleblower who sued his client’s adversary for violating the False Claims Act. No. 13-cv-00085 (S.D. Miss. June 3, 2015). Attorney Holmes had been representing an insurance company in an arbitration proceeding opposite Northrop Grumman regarding insurance coverage. During the proceeding, Holmes obtained documents from the U.S. Navy that were subject to a protective order, which he then used as the basis of his FCA claim against Northrop Grumman. In disqualifying Holmes as a whistleblower, the court found that he had breached his ethical duty to act with candor because he intended to violate the protective order by using documents from the U.S. Navy to support his FCA action. The court rejected Holmes’s argument that the FCA preempts any ethical rules that may have prohibited his actions.