Payne v. District of Columbia Government, et al., No. 11-7116 (D.C. Cir. 2013)
Annotate this CasePlaintiff sued the district and others for violation of, inter alia, the District of Columbia Whistleblower Protection Act (DCWPA), D.C. Code 1-615.52-.54. The district court granted judgment in favor of defendants on all claims and plaintiff subsequently appealed. The court affirmed the judgment because the relevant statute provided no cause of action against individuals and an amendment to the statute passed in 2009 so providing was not retroactive. Further, plaintiff had not established causation between his allegedly protected activity and his discharge.
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