Labor & Employment Advisory: California Supreme Court Upholds Worker-Friendly Evidentiary Standard For Whistleblower Retaliation Suits | News & Insights | Alston & Bird: Super Pumped | Official Site

Before the case reached the California Supreme Court, the U. S. District Court for the Central District of California held for PPG after determining that the McDonnell Douglas test applied to the litigation. The ruling is a win for health care employers in that it will give them the opportunity to present legitimate, non-retaliatory reasons for employee disciplinary actions, then again shift the burden to plaintiffs to show evidence that their decisions were pretextual. The plaintiff in the case, Arnold Scheer, M. D., sued his former employer and supervisors after he was terminated in 2016 from his job as chief administrative officer of the UCLA Department of Pathology and Laboratory Medicine. Under that framework, the employee first must state a prima facie case showing that the adverse employment action was related to the employee's protected conduct. McDonnell Douglas tries to find a single true reason for the employer's action whereas the 1102. Lawson appealed the district court's order to the Ninth Circuit. In its recent decision of Wallen Lawson v. PPG Architectural Finishes, Inc., the California Supreme Court acknowledged the use of the two different standards by trial courts over the years created widespread confusion. Lawson did not agree with this mistinting scheme and filed two anonymous complaints.

1. Labor & Employment Advisory: California Supreme Court Upholds Worker-Friendly Evidentiary Standard for Whistleblower Retaliation Suits | News & Insights | Alston & Bird
2. Lawson v. PPG Architectural Finishes, Inc., No. S266001, 2022 Cal. LEXIS 312 (Jan. 27, 2022
3. California Dances Away From The Whistleblower Three-Step | Seyfarth Shaw LLP
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Labor & Employment Advisory: California Supreme Court Upholds Worker-Friendly Evidentiary Standard For Whistleblower Retaliation Suits | News & Insights | Alston & Bird

As a TM, Plaintiff reported directly to a Regional Sales Manager ("RSM"). The California Supreme Court issued its recent decision after the Ninth Circuit asked it to resolve the standard that should be used to adjudicate retaliation claims under Section 1102. The import of this decision is that employers must be diligent in maintaining internal protective measures to avoid retaliatory decisions. WALLEN LAWSON v. PPG ARCHITECTURAL FINISHES, INC.

In 2017, plaintiff Wallen Lawson, employed by PPG Architectural Finishes, Inc. (PPG), a paint and coatings manufacturer, was placed on a performance improvement plan after receiving multiple poor evaluations. At that time the statute enumerated a variety of substantive protections against whistleblower retaliation, but it did not provide any provision setting forth the standard for proving retaliation. Majarian Law Group, APC. The McDonnell Douglas test allowed PPG to escape liability because PPG was able to present legitimate, non-retaliatory reasons for firing Mr. Lawson despite Mr. Lawson showing that he had been retaliated against due to his reporting of the mistinting practice. This is an employment dispute between Plaintiff Wallen Lawson and his former employer, Defendant PPG Architectural Finishes, Inc. ). The two-part framework first places the burden on the plaintiff to prove that it was more likely true than not that retaliation was a contributing factor in their termination, then the burden shifts to the defendant to show by "clear and convincing evidence" that it had legitimate, nonretaliatory reasons to terminate the plaintiff. Considering the history of inconsistent rulings on this issue, the Ninth Circuit asked the California Supreme Court for guidance on which test to apply when interpreting state law. The employer's high evidentiary standard thus will make pre-trial resolution of whistleblower retaliation claims extremely difficult. 792 (1973), or the more employee-friendly standard set forth in Labor Code section 1102. 6, an employer must show by the higher standard of "clear and convincing evidence" that it would have taken the same action even if the employee had not blown the whistle.

Lawson V. Ppg Architectural Finishes, Inc., No. S266001, 2022 Cal. Lexis 312 (Jan. 27, 2022

Specifically, the lower court found that the employee was unable to prove that PPG's legitimate reason for terminating him – his poor performance – was pretextual, as required under the third prong of the legal test. Although the California legislature prescribed a framework for such actions in 2003, many courts continued to employ the well-established McDonnell Douglas test to evaluate whistleblower retaliation claims, causing confusion over the proper standard. In short, section 1102. At the summary judgment stage, the district court applied the three-part burden-shifting framework established in McDonnell Douglas Corp. v. Green, 411 U. According to Wallen Lawson, his supervisor allegedly ordered him to engage in fraudulent activity.

However, in resolving this dispute, the Court ultimately held that section 1102. California Labor Code Section 1002. It first requires the employee to prove by a preponderance of the evidence that the whistleblowing activity was a "contributing factor" to his termination. 6 provides the correct standard. 6, however, many courts instead applied the familiar burden- shifting framework established by a 1973 U. S. Supreme Court case, McDonnell Douglas v. Green, to claims under section 1102. PPG eventually told Lawson's supervisor to discontinue the practice, but the supervisor remained with the company, where he continued to directly supervise Lawson. The employee appealed to the Ninth Circuit Court of Appeals arguing that the lower court applied the wrong test.

California Dances Away From The Whistleblower Three-Step | Seyfarth Shaw Llp

There are a number of state and federal laws designed to protect whistleblowers. 5 and the applicable evidentiary standard. What does this mean for employers? The California Supreme Court responded to the Ninth Circuit Court of Appeals' request on January 27, 2022.

Prior to the 2003 enactment of Labor Code Section 1102. The defendants deny Scheer's claims, saying he was fired instead for bullying and intimidation. Already a subscriber? 5 retaliation plaintiffs to satisfy McDonnell Douglas to prove that retaliation was a contributing factor in an adverse action, particularly when the third step of McDonnell Douglas requires plaintiffs to prove that an employer's legitimate reason for taking an adverse action is pretext for retaliation. The McDonnell Douglas framework is typically used when a case lacks direct evidence. 5 prohibits employers from retaliating against employees for disclosing information the employee has reasonable cause to believe is unlawful. The Ninth Circuit's Decision. Lawson sued PPG in a California federal district court, claiming that PPG fired him in violation of Labor Code section 1102. Defendant's Statement of Uncontroverted Facts ("SUF"), Dkt.

If you are involved in a qui tam lawsuit or a case involving alleged retaliation against a whistleblower, it is in your best interest to contact an experienced attorney familiar with these types of cases. 6 effectively lowers the bar for employees by allowing them to argue that retaliation was a contributing reason, rather than the only reason. After this new provision was enacted, some California courts began applying it as the applicable standard for whistleblower retaliation claims under Section 1102. ● Reimbursement for pain and suffering. 5 are to be analyzed using the "contributing factor" standard in Labor Code Section 1102. This ruling is disappointing for healthcare workers, who will still need to clear a higher bar in proving their claims of retaliation under the Health & Safety Code provision. On January 27, the California Supreme Court answered the Ninth Circuit's certified question by holding that Section 1102.

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