For Whom The Whistle Blows

I. Introduction

No man is an island, entire of itself; every man is a piece of the continent, a part of the main. If a clod be washed away by the sea, Europe is the less, as well as if a promontory were, as well as if a manor of thy friend's or of thine own were. Any man's death diminishes me because I am involved in mankind; and therefore never send to know for whom the bell tolls; it tolls for thee.¹

With the media attention on Enron and Sarbanes Oxley, employers may comfort themselves by viewing whistleblower law as a source of liability which may be narrowed to a single law, a single type of violation, or even a single type of employer. In reality, whistleblower protection defies legal and industrial boundaries, and courts continue to expand safeguards depending upon the unique circumstances of each case. As a result, employers cannot look to a single statute or legal principle to determine potential liability. Instead, coupling an understanding of fundamental sources of