14 KILLGORE V. SPECPRO PRO. SERV. LLC
investigate or correct the violation.” Lawson, 12 Cal. 5th at
709 (emphasis added) (ellipsis in original). While the
Lawson court was addressing a different question about the
proper framework for evaluating section 1102.5 claims, id.
at 712, the distinction it draws between disclosures to
government agencies, persons with authority over the
whistleblower, or other employees with authority to
investigate or correct the violation, lends further support to
a reading of the statute that makes these avenues of
disclosure independent of one another.
Finally, such a construction is consistent with the broad
remedial purpose of the California Whistleblower Protection
Act. Section 1102.5 “reflects the broad public policy interest
in encouraging workplace whistle-blowers to report
unlawful acts without fearing retaliation.” Green v. Ralee
Eng’g Co., 19 Cal. 4th 66, 77 (1998). When first enacted in
1984, the whistleblower statute provided protection only for
employees who reported suspected violations of law to
outside government or law enforcement agencies. Id. at 76-
77. In 2014, the California Legislature amended section
1102.5(b) to protect employees from retaliation against
disclosure to “a person with authority over the employee or
another employee who has the authority to investigate,
discover, or correct the violation” as well as retaliation “for
providing information to, or testifying before, any public
body conducting an investigation, hearing or inquiry.” 2013
Cal. Stats., ch. 577, § 5.5 (S.B. 666); ch. 732, § 6.5 (Assemb.
B. 263); ch. 781, § 4.1 (S.B. 496). As amended, section
1102.5(b) further clarified that employee disclosures were
protected “regardless of whether disclosing the information
is part of the employee’s job duties.” Id. Other amendments
were made concurrently to the California Business and
Professions Code, Labor Code, and Government Code. Id.
Senate Bill 496 was intended to “clarif[y] rights and
procedures under the California Whistleblower Protection