14) March 2, 2012 The Virginia Supreme Court rules in the University of Virginia's favor in the Mann case, with the majority finding that the university is not a «person» as defined in the Fraud Against Taxpayers Act (FATA), and therefore the Attorney General has no authority under the Act to
make civil investigative demands (CIDs) of the university.
She went on, at paras. 103 and 106, to
make the point that litigants in a
civil proceeding should not be able to use article 402 to circumvent the requirements of probable cause and
investigative necessity.