SOX Whistleblower Need Not Show Employer’s Retaliatory Intent, Supreme Court Rules

February 21, 2024

 

What's New

A whistleblower claiming unlawful retaliation under the Sarbanes-Oxley (SOX) Act need not show that the employer acted with retaliatory intent to establish a valid claim, the U.S. Supreme Court ruled February 8, 2024. Instead, a plaintiff need show only that the protected activity was a contributing factor to the adverse action. The burden then shifts back to the employer to prove that it would have taken the same action regardless of the whistleblower’s protected activity. The Supreme Court’s ruling in Murray v. UBS Securities resolves a split between the U.S. Court of Appeals for the Second Circuit and the Fifth and Ninth Circuits.

The case arose when Trevor Murray, then a research strategist at UBS who wrote reports about the firm’s securities business, alleged that the company fired him shortly after he told his supervisors that two of the company’s trading desk leaders were trying to influence his independent reporting. The company said that business losses required them to eliminate some jobs, including Murray’s.

What It Means

This ruling will make it easier for a SOX whistleblower to prevail on a SOX retaliation claim, but it also affirms that an employer can still defeat a claim by showing that it would have taken the same adverse action even without the plaintiff’s protected activity.

What You Should Do

Employers must be particularly careful when taking an adverse action against an employee who allegedly engaged in recent protected activity. Employers should ensure that the reason for the adverse action is well-documented and unrelated to the employees' protected activity.





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