United States District Court, District of Minnesota v. Edwards Lifesciences, LLC

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The 2013 amendment to the Minnesota Whistleblower Act defining the term “good faith” eliminated the judicially created requirement that the putative whistleblower act with the purpose of “exposing an illegality.” Appellant filed a complaint in the United States District Court for the District of Minnesota alleging that Employer wrongfully terminated his employment in violation of the Minnesota Whistleblower Act. Employer argued in response that Defendant’s conduct was not protected under the Act. Employer based this argument on the Supreme Court’s interpretation of the Act in Obst v. Microtron, Inc., 614 N.W.2d 196, 202 (Minn. 2000), in which the court held that “good faith” requires a putative whistleblower to act with the purpose of “exposing an illegality.” Appellant argued in response that Obst is no longer good law following a 2013 amendment to the Act that defines “good faith” to mean “conduct that does not violate section 181.932, subdivision 3.” The district court certified the question to the Supreme Court as to whether the 2013 amendment abrogated the Supreme Court’s prior interpretation of “good faith.” The Supreme Court answered the certified question in the affirmative. View "United States District Court, District of Minnesota v. Edwards Lifesciences, LLC" on Justia Law