No Whistleblower Action If No Economic Harm To State Alleged.

The trial court granted summary judgment to the employer, and the appellate court reversed, stating: “We reverse the summary judgment on three of [plaintiff’s] causes of action, and affirm the judgment for [employer defendant] on two others. Because [plaintiff] did not demonstrate that the fraud alleged in one of his causes of action under the CFCA involved possible financial harm to the state, summary judgment was proper on that claim. We conclude as to his other CFCA cause of action that [plaintiff] alleged possible fraud on the government that caused it economic harm and that his reporting of fraud was protected conduct. We also conclude that the Labor Code protects an employee from discrimination for reporting claims of illegal conduct by fellow employees as well as by an employer.” McVeigh v. Recology San Francisco  (Cal. App. First Dist., Div. 3; January 31, 2012) 213 Cal.App.4th 443.