THE AMERICAN LAW INSTITUTE Continuing Legal Education Advanced Employment Law and Litigation 2015 March 26-28, 2015 Washington, D.C.

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1 1349 THE AMERICAN LAW INSTITUTE Continuing Legal Education Advanced Employment Law and Litigation 2015 March 26-28, 2015 Washington, D.C. Whistleblower Litigation By Debra S. Katz Katz, Marshall & Banks, LLP Washington, D.C. Debra S. Katz is a founding partner with Katz, Marshall & Banks, LLP, a civil rights firm based in Washington, D.C., that specializes in the representation of plaintiffs in employment law, whistleblower civil rights and civil liberties matters. Copyright 2015, Debra S. Katz, Marshall & Banks, LLP, Washington, D.C.

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3 1351 Table of Contents 1 I. OSHA-ADMINISTERED WHISTLEBLOWER PROTECTIONS: AN OVERVIEW... 1 A. CONSUMER AND INVESTOR PROTECTION WHISTLEBLOWER PROVISIONS... 1 B. ENVIRONMENTAL AND NUCLEAR SAFETY WHISTLEBLOWER PROVISIONS C. TRANSPORTATION INDUSTRY WHISTLEBLOWER PROVISIONS II. SARBANES-OXLEY WHISTLEBLOWER PROTECTION... 7 A. INTRODUCTION... 7 B. COVERED EMPLOYERS... 8 C. COVERED EMPLOYEES D. PROTECTED ACTIVITY E. PROHIBITED RETALIATION F. THE LITIGATION PROCESS G. AVAILABLE REMEDIES III. THE DODD-FRANK ACT A. COMMODITY FUTURES TRADING COMMISSION WHISTLEBLOWER INCENTIVE PROGRAM B. SECURITIES AND EXCHANGE COMMISSION (SEC) WHISTLEBLOWER INCENTIVE PROGRAM AND ANTI- RETALIATION PROVISIONS C. WHISTLEBLOWER PROTECTIONS FOR FINANCIAL SERVICES EMPLOYEES IV. OTHER CONSUMER AND INVESTOR PROTECTION WHISTLEBLOWER PROVISIONS A. THE AFFORDABLE CARE ACT, 29 U.S.C. 218C B. THE CONSUMER PRODUCT SAFETY IMPROVEMENT ACT, 15 U.S.C C. FDA FOOD SAFETY MODERNIZATION ACT WHISTLEBLOWER PROTECTIONS V. GOVERNMENT CONTRACTOR WHISTLEBLOWER PROTECTIONS A. DEFENSE CONTRACTOR WHISTLEBLOWER PROTECTIONS, 10 U.S.C B. GOVERNMENT CONTRACTOR AND SUBCONTRACTOR PILOT PROGRAM, 41 U.S.C VI. FALSE CLAIMS ACT WHISTLEBLOWER PROTECTIONS A. QUI TAM SUITS B. ANTI-RETALIATION PROVISION VII. AMERICAN RECOVERY AND REINVESTMENT ACT WHISTLEBLOWER PROTECTIONS. 86 A. COVERED ENTITIES B. PROTECTED ACTIVITY C. PROHIBITED RETALIATION D. PROVING RETALIATION E. LITIGATION PROCESS AND AVAILABLE REMEDIES F. NO PROSPECTIVE WAIVER OF CLAIMS Internal Pagination i

4 ALI-CLE Whistleblower Litigation I. OSHA-ADMINISTERED WHISTLEBLOWER PROTECTIONS: AN OVERVIEW 2 The Occupational Health and Safety Administration ( OSHA ) is charged with enforcing twenty-one nuclear, environmental, health, and consumer protection statutes. The past few years have indicated a sea change with respect to the aggressiveness with which OSHA is investigating, pursuing, and enforcing many of these provisions. This change extends up through the Department of Labor s Administrative Review Board ( ARB ), the body charged with final administrative review of the findings of OSHA, in the first instance, and the Administrative Law Judge ( ALJ ), who acts as the first level of review. Many but not all of the statutes provide for judicial review of the ARB decision in the appropriate United States Court of Appeals. This paper first outlines the statutory framework, coverage, and protections of the statutes enforced by OSHA. Following that, in Section II, it discusses recent developments in whistleblower law. Because many of these statutes share identical (or very similar) frameworks, and are enforced by the same governing body, the holding or rationale of a case decided under one statute is likely to be applicable to cases arising under many of the other statutes as well. Finally, in Section III, it discusses the current revitalization of OSHA, with a focus on its 2011 updated manual, which increased protections for whistleblowers. A. Consumer and Investor Protection Whistleblower Provisions 3 OSHA enforces the whistleblower protection provisions of five consumer and investor protection laws: the Affordable Care Act, 29 U.S.C. 218C ( ACA ); the Consumer Financial Protection Act, 12 U.S.C ( CFPA ); the Consumer Product Safety Improvement Act, 15 U.S.C ( CPSI ); Food Safety Modernization Act, 21 U.S.C. 399d ( FSMA ); and the Sarbanes-Oxley Act, 18 U.S.C. 1514A ( SOX ). These statutes require a complainant to show that her protected activity was a contributing factor in the adverse personnel action and provide an aggrieved party with potential remedies of reinstatement to his or her former position with back pay, compensatory damages, and special damages sustained as a result of the discharge or 2 This whistleblower litigation update will focus largely on developments in the law governing retaliation claims brought under the Sarbanes-Oxley Act, 18 U.S.C. 1514A; the Dodd-Frank Act, 15 U.S.C. 78u-6; the False Claims Act, 31 U.S.C. 3730(h); the 2013 National Defense Authorization Act, 10 U.S.C. 2409; Affordable Care Act, 29 U.S.C. 218C; the Consumer Financial Protection Act, 12 U.S.C. 5567; the Consumer Product Safety Improvement Act, 15 U.S.C. 2087; and the Food Safety Modernization Act, 21 U.S.C. 399d ( FSMA ). For summaries of decisions related to the other OSHA-administered whistleblower statutes, including those protecting whistleblowers in the environmental and transportation industries, see the Department of Labor Office of Administrative Law Judges summaries of federal court decisions relating to OSHA-administered statutes for 2014 and 2015, available at 3 Several of the new and more commonly-litigated consumer and investor protection whistleblower statutes are described in greater detail herein. 1

5 ALI-CLE Whistleblower Litigation discrimination, including litigation costs, expert witness fees, and reasonable attorneys fees. A brief overview of each statute is as follows: Affordable Care Act, 29 U.S.C. 218C ( ACA ): Protects employees who report violations of any provision of title I of the ACA, including but not limited to discrimination based on an individual s receipt of health insurance subsidies, the denial of coverage based on a preexisting condition, or an insurer s failure to rebate a portion of an excess premium. An employee must file a complaint with OSHA within 180 days. Enforcement procedures and judicial review are provided for in 29 U.S.C. 2087, the whistleblower protections of the Consumer Product Safety Consumer Act. Consumer Financial Protection Act, 12 U.S.C ( CFPA ): Employees are protected for blowing the whistle on reasonably perceived violations of any provision of the Title X of the Dodd-Frank Wall Street Reform and Consumer Protection Act or any other provision of law that is subject to the jurisdiction of the Bureau of Consumer Financial Protection, or any rule, order, standard, or prohibition prescribed by the Bureau. An employee must file a complaint with OSHA within 180 days. Covered employees include any individuals performing tasks related to the offering or provision of a consumer financial product or service. Consumer Product Safety Improvement Act, 15 U.S.C ( CPSIA ): Protects employees who report to their employer, the federal government, or a state attorney general reasonably perceived violations of any statute or regulation within the jurisdiction of the Consumer Product Safety Commission. CPSIA covers employees of consumer product manufacturers, importers, distributors, retailers, and private labelers. An employee must file a complaint with OSHA within 180 days. FDA Food Safety Modernization Act, 21 U.S.C. 399d ( FSMA ): Protects employees of food manufacturers, distributors, packers, and transporters from reporting a violation of the Food, Drug, and Cosmetic Act, or a regulation promulgated under the Act. Employees are also protected from retaliation for refusing to participate in a practice that violates the Act. An employee must file a complaint with OSHA within 180 days. The whistleblower protections created by Section 402 broadly apply to employees of any entity engaged in the manufacture, processing, packing, transporting, distribution, reception, holding, or importation of food. 402(a). Sarbanes-Oxley Act, 18 U.S.C. 1514A ( SOX ): Protects employees of certain companies who report alleged mail, wire, bank or securities fraud; violations of the SEC rules and regulations; or violation of federal laws related to fraud against 2

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