Corporate,
9th U.S. Circuit Court of Appeals
Mar. 31, 2017
Internal whistleblower reports are protected
A divided 9th Circuit panel said a company's retaliation for internal reports is actionable under Dodd-Frank.






W. Hardy Callcott
Sidley Austin LLP
555 California St Ste 2000
San Francisco , CA 94104
Phone: (415) 772-7402
Fax: (415) 772-7400
Email: hcallcott@sidley.com
Stanford Univ Law School; Stanford CA
W. Hardy Callcott is a partner at Sidley Austin LLP.

Ami N. Wynne
Phone: 312 853 7752
Email: awynne@sidley.com
Ami N. Wynne is a partner at Sidley Austin LLP.
This month, a divided panel of the 9th U.S. Circuit Court of Appeals issued a decision finding that a company's retaliation against a whistleblower is actionable under the Dodd-Frank Act, even if the whistleblower reports internally rather than to the Securities and Exchange Commission. Somers v. Digital Realty Trust Inc., 2017 DJDAR 2150 (March 8, 2017). Circuit courts and district courts have disagreed on this issue. In its decision, the 9th Circuit followed a ruling by the 2nd ...
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