Local false claims laws let cities recover money lost to fraud on city contracts, protect the employees who report it, and fill gaps that state law leaves open. Here is what the laws say, who enforces them, and what they have actually recovered.

Jeff Newman, Esq., MBA Jeff Newman Law  |  November 2026

In February 2010, Philadelphia did something few American cities have done. It wrote its own false claims law.

The ordinance, enacted as Bill No. 090467 and approved on February 3, 2010, sits at Sections 19-3601 through 19-3606 of the Philadelphia Code. It borrows the architecture of the federal False Claims Act, the Civil War–era statute that lets private citizens bring fraud cases on the government’s behalf and share in what is recovered.

Under the ordinance, anyone who knowingly presents a false claim to the City, or uses a false record to get one paid, is liable for three times the City’s damages, plus fines and attorneys’ fees. No proof of a specific intent to defraud is required. Reckless disregard of the truth is enough.

The timing matters. Pennsylvania still has no state False Claims Act, for reasons set out below. Until that changes, Philadelphia and Allegheny County are the only places in Pennsylvania with a local law of this kind.

Why Pennsylvania still has no state False Claims Act

Pennsylvania is not without a whistleblower statute. Its Whistleblower Law, 43 P.S. §§ 1421–1428, prohibits retaliation and discrimination. What the Commonwealth lacks is a state False Claims Act: a law that lets a private citizen sue on the Commonwealth’s behalf and share in what is recovered.

It is not for lack of trying. False claims bills passed the state House unanimously in 1999 and 2001, then stalled in the Senate, and similar measures were introduced in almost every session from 2005 to 2025 without progressing. Rep. Frank Burns, the House sponsor of the current effort, says Pennsylvania is the largest state without one. Three arguments have kept it that way.

1. Opposition from health care and business groups

The Hospital and Healthsystem Association of Pennsylvania and the Pennsylvania Health Care Association have been vocal opponents. They argue that a state Act would invite “trivial claims” and divert money from patient care into compliance costs and litigation, and they point in particular to financially fragile and rural hospitals. An industry stakeholder letter to the state Senate argued that the law would reach inadvertent errors rather than intentional fraud, and that treble damages and per-claim penalties would make it impossible for small entities to survive the litigation.

2. Disputes over the money

Under the pending bills, a whistleblower could receive 15 to 30 percent of a recovery, comparable to the federal law. The Pennsylvania Coalition for Civil Justice Reform objects that personal injury lawyers may pocket a significant portion of what the state recovers, and that revenue projections from a state Act are speculation.

Supporters answer with federal money Pennsylvania is leaving on the table. Under the Deficit Reduction Act of 2005, when a state’s False Claims Act is approved by the Inspector General of the U.S. Department of Health and Human Services, the federal share of Medicaid recoveries from actions under that law drops by 10 percentage points, and the state keeps the difference. Sen. Lindsey Williams, a sponsor of the Senate version, argues that protecting the employees who see fraud first, and who come forward to report it, is the best way to detect and deter it.

3. The Attorney General’s existing authority

Opponents also argue that a state Act would duplicate tools the Commonwealth already has, including the Attorney General’s consumer protection powers and the criminal Medicaid fraud prosecutions brought by its Medicaid Fraud Control Section. Supporters reply that the bills would not replace the existing Whistleblower Law but would fill a gap in it.

Where it stands now

Governor Josh Shapiro called for a state Act in his 2026–27 budget address. In October 2026, the state House attached false claims provisions to Senate Bill 115 and passed it 139 to 64. The bill returned to the Senate, where it was referred to the Rules and Executive Nominations Committee on October 19, 2026. As of this writing, that is the last recorded action, and the bill is not law.

A short list

Philadelphia is not alone, but the company is small. Local governments with their own false claims laws include:

• New York City — Local Law 53 of 2005, New York City Administrative Code § 7-801 et seq. Mayor Michael Bloomberg signed it on May 19, 2005; it was extended and amended in 2012.
• Chicago — Municipal Code § 1-22-010 et seq., dating to 2004 according to practitioner summaries.
• Philadelphia — Philadelphia Code §§ 19-3601 to 19-3606, 2010.
• Allegheny County, Pennsylvania — County Code, Chapter 485.
• Miami-Dade County, Florida — County Code § 21-255 et seq., enacted by Ordinance No. 99-152 in 1999.
• Broward County, Florida — Ordinance No. 2002-18, County Code § 1-276 et seq.

At least one practitioner list also names two smaller Florida municipalities, Bay Harbor Islands and Hallandale Beach. I have not reviewed those ordinances and do not rely on them here. Another practitioner summary counts the District of Columbia among local jurisdictions with a false claims law, though D.C. is a federal district rather than a city in the ordinary sense.

California took a different road. Its cities did not need their own ordinances, because the state’s False Claims Act already covers money taken from a “political subdivision.” The statute names the city attorney or county counsel as the local “prosecuting authority” responsible for investigating and litigating claims involving local funds.

Why cities write their own laws, and why the other cities should do so as well

The ordinances themselves, and the officials who enforce them, give the reasons. Six stand out.

1. To recover the city’s own money

New York City’s Law Department describes its Act as an additional tool for recovering damages from parties who file fraudulent claims for payment of City funds. That is the core of every one of these laws: the city is the victim, and the city recovers.

There is a structural reason this matters. When fraud runs through a state program, the money may go to the state. New York City’s Law Department notes that, absent express state approval, the City receives no monetary benefit from successfully litigating Medicaid claims; those recoveries go to New York State. A city law aimed at city contracts, grants and fees keeps the recovery at home.

2. To deter

Miami-Dade County put the purpose in the text. Its ordinance says it exists to deter people from knowingly causing the County to pay claims that are false, fraudulent or inflated, and to provide remedies for recovering damages. Treble damages and penalties are meant to make the arithmetic of padding a city invoice unattractive before anyone is caught.

3. To reach the people who know

Fraud on a city contract is rarely visible from City Hall. It is visible to the bookkeeper who sees two sets of timesheets, the foreman who knows the certified subcontractor never showed up, the project manager who watched a change order inflate. The ordinances are built to bring that knowledge forward. Philadelphia requires a person’s proposed complaint to be signed, verified, and accompanied by all of the material evidence the person has.

4. To fill a gap in state law

Pennsylvania has no state Act. In Florida, the state Act does not reach municipalities: according to a summary of Florida Attorney General Opinion 2011-10, the Attorney General concluded that the state law does not apply to cities, and noted that Miami-Dade and Broward had adopted their own ordinances. Where the state leaves a gap, a local law is the only false claims remedy the local treasury has.

5. To protect employees who come forward

Philadelphia’s ordinance forbids an employer from firing, demoting, suspending, threatening or harassing an employee for lawful acts in furtherance of a false claims action. An employee who suffers retaliation is entitled to be made whole: reinstatement with seniority, back pay with interest, special damages, and attorneys’ fees.

6. To reach fraud that is distinctly local

This last reason is my own reading of the cases rather than a stated legislative purpose. The matters brought under these laws are often too local, or too small, to draw a federal prosecutor. In Chicago they have involved a city residency requirement written into construction contracts, home-repair permits, and unremitted lease taxes. New York City’s 2024 report sorts its open matters into overcharges, underpayments and tax claims. These are frauds against the city as a buyer, a permitting authority and a tax collector.

How Philadelphia’s ordinance works

Philadelphia did not simply copy the federal statute. It built a gatekeeper.

Under the federal Act, a whistleblower files suit under seal and the government decides whether to take it over. Under Philadelphia’s ordinance, the whistleblower does not file anything in court at first. The person submits a proposed civil complaint to the City Solicitor, or to another officer the Mayor designates. After investigating, the Solicitor may:

• bring the case in the City’s name;
• designate the person who submitted the complaint, or that person’s attorney, to file the case in the City’s name;
• decline to proceed and decline to designate anyone; or
• proceed in any other manner the Solicitor considers appropriate.

The ordinance is explicit that no one other than the City Solicitor, or a person the Solicitor designates, may sue on the City’s behalf. Even when a designated relator is litigating, the Solicitor keeps sole authority to settle, subject to the court’s approval, and the City is not bound by the relator’s acts.

The rewards track the federal model. If the Solicitor brings the case, the people who submitted the complaint collectively receive between 10 and 25 percent of the proceeds. If a designated person brings it, the share is between 15 and 30 percent. If the Solicitor pursues an alternative remedy based on the submission, the person keeps the same entitlement to a share of any cash recovered. A person convicted of criminal conduct arising from the violation receives nothing.

Three limits stand out. The ordinance does not apply to tax claims, although, according to a 2018 practitioner summary, a separate part of the Philadelphia Code permits private actions over wage tax and net profits tax violations. It does not apply to claims with a cumulative value under $10,000. And it does not apply to claims against the City itself, the Commonwealth or the federal government. Information a person submits is confidential to the fullest extent the law allows.

Who enforces these laws

• Philadelphia: the City Solicitor, or another officer the Mayor designates to investigate.
• New York City: proposed complaints go to the Department of Investigation, which reviews them and forwards them to the Law Department; the Corporation Counsel has assigned false claims matters to its Affirmative Litigation Division.
• Chicago: the City acts through its Department of Law, which signed the 2024 ResiPro settlement.
• Miami-Dade County: a qui tam complaint is filed under seal in the circuit court of the Eleventh Judicial Circuit.
• California cities and counties: the city attorney or county counsel, as the local prosecuting authority under the state Act.

Working alongside state and federal law

A city ordinance does not displace state or federal law. It is an additional count in the same complaint.

In a Chicago construction case, a relator filed in 2017 asserting federal, state and city false claims counts together, based on alleged noncompliance with the City’s residency ordinance in six city contracts. The City intervened in November 2019. In the 2024 ResiPro matter, a single settlement resolved claims under both Chicago’s ordinance and the Illinois False Claims Act. New York City’s Law Department reports that it uses the state Act, in addition to its local law, to pursue these cases.

The layering creates traps. In 2018, a federal settlement in Chicago included a standard release purporting to cover claims on behalf of any state or political subdivision. The City objected, because it held its own claims under its ordinance against the same defendants. Counsel settling a federal case that touches city money need to read the release with the city in mind.

What the laws have actually recovered

Here the record becomes more interesting, and more sobering, than the statutes suggest. The largest recoveries tied to these cities were obtained by city and federal lawyers. In several of them, the whistleblower who came forward received nothing.

Matter	Year	What the city recovered	What the whistleblower received
New York City / SAIC (CityTime payroll system)	2012	More than $500 million through a federal deferred prosecution agreement; $466 million remitted to the City	Nothing. Relator’s request for a share denied because his own qui tam claims had been dismissed (S.D.N.Y. 2017)
New York City / Bank of New York Mellon (foreign-exchange pricing)	2016	$30 million City settlement, reached on non-false-claims counts after the City Act counts were dismissed in 2013	Nothing. Relator rejected the City’s payment offer; appellate court held no share was due (1st Dept. 2021)
Chicago / Redflex (red-light camera contract)	2017	$20 million settlement resolving the City’s suit, which included a False Claims Ordinance count	Nothing. Original relator dismissed under the public-disclosure bar; share and fees denied
San Francisco / Old Republic (California state Act)	2006	City sued as the relator itself under the state Act	The City, as relator, was awarded one-third of the trebled damages: $7.568 million
New York City / Siemens Electrical (state and City Acts)	2021	$1.5 million settlement	20 percent: $300,000
Chicago / ResiPro (home-repair permits)	2024	$543,600 on the False Claims Ordinance count, within a $2.2 million settlement	25 percent of the City’s ordinance recovery: $90,720

A few of these deserve a word of explanation.

The CityTime recovery is the largest, but it did not come through a judgment under the City’s Act. SAIC, the lead contractor on the City’s payroll-automation project, entered a federal deferred prosecution agreement, and the United States remitted $466 million of a $500 million payment to the City. A relator who had filed state and City false claims counts asked for a share. The court denied it in 2017, holding that a relator must have a valid qui tam action of his own before he can share in an alternate recovery, and his claims had been dismissed.

The Bank of New York Mellon case followed a similar path. The relator filed under the state Act; the City and State intervened and added City Act counts; the court dismissed the false claims counts in 2013. The State later settled for about $167 million and paid the relator a $2 million fee. In December 2016, the City settled its remaining claims for $30 million and offered the relator a payment, which the relator rejected. In 2021 the Appellate Division held that a relator whose claims were dismissed for failure to state a cause of action is not entitled to a share.

Chicago’s Redflex settlement is the clearest example of a city ordinance case producing a large recovery. The City’s amended complaint alleged violations of its False Claims ordinance along with bribery- and kickback-related claims over its red-light camera program, and the $20 million settlement resolved them all. The man who first filed under the ordinance in 2014 was dismissed under the public-disclosure bar, and his request for a share and fees was denied.

The smaller cases are where the system worked as written. In the Siemens Electrical matter, which alleged in part that the contractor misrepresented its qualifying business status, the relator received 20 percent of a $1.5 million settlement. In Chicago’s ResiPro matter, the relator received 25 percent of the City’s $543,600 ordinance recovery. And in San Francisco, the City itself acted as relator under California’s state Act and was awarded $7.568 million, one-third of the trebled damages.

And Philadelphia?

I could not find a publicly reported recovery under Philadelphia’s ordinance in court decisions, in the Law Department’s published annual reviews, or in press coverage. That is not proof there have been none. The ordinance makes submissions confidential, and a matter the Solicitor resolves quietly may never produce a public record.

The ordinance does appear in the case law. In a 2016 Commonwealth Court decision, a Philadelphia police officer brought a retaliation claim that invoked both the Pennsylvania Whistleblower Law and the False Claims Ordinance. The trial court entered a nonsuit on the ordinance claim, and the court noted that the ordinance by its terms does not apply to claims brought against the City.

What the record teaches

Three lessons emerge.

These laws are used less than they could be. New York City’s own report for 2024 states that the Department of Investigation forwarded no proposed matters to the Law Department that year, and that none of the 18 matters it received from other sources alleged claims under the City’s Act. Where a strong state law exists, the city law tends to ride along behind it.

Procedure decides who gets paid. In the largest cases, relators lost on threshold questions: whether their information had already been publicly disclosed, and whether their own complaint stated a claim. The size of the city’s recovery did not change that answer.

Design shapes behavior. Philadelphia’s gatekeeper model gives the City Solicitor control over whether a case is filed and by whom, and excludes tax claims and claims under $10,000. Those choices protect the City from weak or opportunistic suits. They also mean that the path from an insider’s knowledge to a recovery runs entirely through one office.

The government is the party offering the incentive in every one of these laws. A city that writes a false claims ordinance is asking the people who see fraud from the inside to come forward, and promising them a share of what is recovered and protection if they are punished for it. Whether that promise is kept depends less on the words of the ordinance than on how the path through it actually works.

Jeff Newman Law is a national whistleblower law firm that handles whistleblower cases under the False Claims Act, including healthcare and tariff fraud matters and other kinds of cases. Reach the firm at www.jeffnewmanlaw.com or 617-823-3217.

Sources

Items marked [secondary] are law-firm, press or third-party summaries; all others are statutes, court decisions, or government documents (some as compiled by third-party sites).

1. Philadelphia Code §§ 19-3601 to 19-3606 (Bill No. 090467), text as compiled January 2026. https://whistleblower.law/wp-content/uploads/2026/01/43.Local-Cities-Philadelphia-PA.pdf
2. New York City Law Department, annual report on the New York City False Claims Act for calendar year 2024 (Feb. 27, 2025). https://a860-gpp.nyc.gov/downloads/mc87pt890?locale=en
3. New York City Law Department, New York City False Claims Act overview. https://www.nyc.gov/site/law/public-resources/new-york-city-false-claims-act.page
4. Chicago Municipal Code § 1-22-010 et seq. (compiled text). https://whistleblower.law/wp-content/uploads/2026/01/40.Local-Cities-Chicago-IL.pdf
5. Allegheny County Code ch. 485, False Claims (compiled text). https://whistleblower.law/wp-content/uploads/2026/01/42.Local-Cities-Allegheny-PA.pdf
6. Miami-Dade County False Claims Ordinance, Code § 21-255 et seq. (compiled text). https://whistleblower.law/wp-content/uploads/2026/01/39.Local-Cities-Miami-Dade-FL.pdf
7. Broward County False Claims Ordinance, Ord. No. 2002-18 (compiled text). https://whistleblower.law/wp-content/uploads/2026/01/37.Local-Cities-Broward-County-FL.pdf
8. Comptroller of the City of N.Y. v. Bank of N.Y. Mellon Corp., 200 A.D.3d 58 (1st Dept. 2021). https://nycourts.gov/reporter/3dseries/2021/2021_06033.htm
9. City of New York v. Siemens Elec., LLC (1st Dept. 2021). https://www.nycourts.gov/reporter/3dseries/2021/2021_03405.htm
10. New York ex rel. Khurana v. Spherion Corp., opinion and order on relator’s share (S.D.N.Y. Mar. 28, 2017). https://docs.justia.com/cases/federal/district-courts/new-york/nysdce/1:2015cv06605/446476/84
11. New York City Office of the Mayor, release on the $500 million CityTime payment by SAIC (2012). https://www.nyc.gov/office-of-the-mayor/news/092-12/mayor-bloomberg-investigations-commissioner-gill-hearn-500-million-payment-prime
12. City of Chicago, Office of the Mayor, release on the $20 million Redflex settlement (Feb. 6, 2017). https://www.chicago.gov/city/en/depts/mayor/press_room/press_releases/2017/february/20_Million_Settlement_Between_Chicago_And_Redflex.html
13. City of Chicago ex rel. Rosenberg v. Redflex Traffic Systems, Inc., 884 F.3d 798 (7th Cir. 2018). https://cite.case.law/f3d/884/798/
14. Settlement Agreement, State of Ill. ex rel. Haggerty v. ResiPro, No. 2020 L 007974 (filed Feb. 14, 2024). https://www.Chicago.gov/content/dam/city/depts/dol/supp_info/resipro/SettlementAgreement-Stamped.pdf
15. United States ex rel. Milazzo v. JKCC (N.D. Ill.), opinion describing federal, state and city counts. https://case-law.vlex.com/vid/united-states-v-joel-917009835
16. State ex rel. Harris v. PricewaterhouseCoopers, LLP (Cal. 2006). https://scocal.stanford.edu/opinion/state-ex-rel-harris-v-pricewaterhousecoopers-33666
17. California Government Code §§ 12650–12656 (False Claims Act). https://california.public.law/codes/government_code_section_12652
18. Zenak v. Police Athletic League of Philadelphia (Pa. Commw. Ct. 2016). https://caselaw.findlaw.com/court/pa-commonwealth-court/1722402.html
19. Arnold & Porter, “Settling a False Claims Act Case” (Feb. 2019) [secondary]. https://www.arnoldporter.com/en/perspectives/blogs/fca-qui-notes/posts/2019/02/settling-a-false-claims-act-case
20. Berger Montague, “Philadelphia False Claims Ordinance” (July 26, 2018) [secondary]. https://bergermontague.com/philadelphia-false-claims-ordinance/
21. Summary of Florida Attorney General Opinion 2011-10 [secondary]. https://ezel.ai/ag-opinions/fl/municipality-florida-false-claims-act
22. Pietragallo Gordon Alfano Bosick & Raspanti, on Governor Shapiro’s 2026–27 budget address (JD Supra) [secondary]. https://www.jdsupra.com/legalnews/governor-shapiro-uses-his-annual-budget-8119570/
23. Pennsylvania General Assembly, Senate Bill 115 (2025–2026 Session), bill history (retrieved Nov. 9, 2026). https://www.palegis.us/legislation/bills/2025/sb115
24. Constantine LLP, “State and Local False Claims Acts” (list of local laws) [secondary]. https://constantinellp.com/practice/whistleblower/whistleblower-types/whistleblower-reward-laws/state-local-false-claims-acts/
25. MoloLamken / Mondaq, differences between state and federal whistleblower claims [secondary]. https://webiis08.mondaq.com/unitedstates/white-collar-crime-anti-corruption-fraud/1412924/what-are-the-differences-between-state-and-federal-whistleblower-claims
26. Philadelphia Law Department, 2024 Year in Review. https://www.phila.gov/media/20250613104403/2024-Year-In-Review-Final.pdf
27. Social Security Act § 1909, 42 U.S.C. § 1396h (state false claims act incentive). https://www.ssa.gov/OP_Home/ssact/title19/1909.htm
28. Miller Shah LLP, “Renewed Push for Pennsylvania False Claims Act Builds on Local Successes in Philly and Allegheny County” (Aug. 4, 2025) [secondary]. https://millershah.com/blog/pennsylvania-false-claims-act/
29. Miller Shah LLP, “Anti-Fraud Coalition Urges Pennsylvania Lawmakers to Pass State False Claims Act” (2026) [secondary]. https://millershah.com/blog/anti-fraud-coalition-pennsylvania-false-claims-act/
30. Pennsylvania Coalition for Civil Justice Reform, “False Claims Act” issue page [secondary; advocacy]. https://paforciviljusticereform.org/issues/false-claims-act/
31. Industry stakeholder letter to members of the Pennsylvania Senate opposing a state False Claims Act [secondary; advocacy]. https://assets.noviams.com/novi-file-uploads/pstap/Advocacy/False_Claims_Act-_Stakeholder_Letter.pdf
32. Spotlight PA, “False claims laws in other states have brought in millions. Why hasn’t it passed in Pa.?” (Feb. 2026) [secondary]. https://www.spotlightpa.org/news/2026/02/whistleblower-false-claims-pennsylvania-shapiro-capitol/
33. Pennsylvania Record, “Critics sound alarm on whistleblower bill in Pennsylvania” (July 2025) [secondary]. https://www.legalnewsline.com/pennsylvania-record/pennsylvania-record/critics-sound-alarm-on-whistleblower-bill-in-pennsylvania/article_b4bcc228-885f-43e4-a38f-eaeb207f8ff7.html