The Fifth Circuit affirmed the dismissal of a qui tam action against Northrop Grumman and the disqualification of the attorney from serving as the relator in the False Claims Act lawsuit due to the attorney’s misconduct.  U.S. ex rel. Holmes v. Northrup Grumman Corp., No. 15-60414 (5th Cir. Mar. 23, 2016).  The attorney represented Munich Re in an arbitration against Northrop Grumman.  During that arbitration, the attorney received documents relating to Northrop Grumman from the United States Navy, pursuant to a protective order preventing the disclosure or use of the documents outside of the arbitration.  The attorney, while the arbitration was pending, filed the qui tam lawsuit against Northrop Grumman, alleging Northrop Grumman defrauded the Navy by using government funds allocated for expenses related to Hurricane Katrina on unrelated costs.  The district court determined, and the Fifth Circuit affirmed, that the attorney, in filing the lawsuit, violated his duty of candor by violating the protective order, and also violated his duty of loyalty to his client, Munich Re, by taking a position adverse to his client in the qui tam litigation.