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Lawson v. Fidelity Management & Research FMR LLC

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Sherron Watkins worked for Enron between 1993 and 2002. When she discovered accounting irregularities in 2001 she reported it. Her supervisors retaliated against her & others who tried to report wrongdoing. Lawson expressed concerns about overstating expenses associated with mutual funds. Zang was fired after raising concerns of inaccuracies after 8 yrs. The Current law at the time provided protection against retaliation for employees, contractors, subcontractors of companies Securities and Exchange act of 1934. Petitioner Jackie Lawson and Jonathan Zang. 14 yr. These employees were contractors.

Defense moved to dismiss arguing that the law only protects employees. 1st Circuit of Appeals agreed with defense interpretation.


Wether the whistleblower protection laws protect independent contractors that not employed by an employer?




The law was intended to protect plaintiffs like Lawson, Zang and Watkins from retaliation for reporting wrongdoing at work place to supervisors. Even though none where employees, they did work for FMR.



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