A California Court of Appeal in Cardenas v. M. Fanaian,
D.D.S., Inc. held that Labor Code § 1102.5, which
protects employees from retaliation for reporting illegal conduct
to law enforcement agencies, applies to an employee's report of
illegal conduct of a private or individual nature unrelated to the
employer's operation or enterprise.
Cardenas was a dental hygienist. She received an expensive ring
from her husband for her twenty-fifth wedding anniversary. Cardenas
wore her new ring to work every day until one day when it went
missing. She had reason to believe that a coworker had stolen the
ring. When she told her boss, he discouraged her from reporting the
incident to the police. Cardenas and her husband went ahead and
filed a police report for theft of the ring. The police visited the
dental office where Cardenas worked a few times to interview
witnesses and collect evidence. After one of the visits,
Cardenas's boss told her that the police investigation
