Somers v. Digital Realty Trust Inc.

(United States Ninth Circuit) – In a whistleblower claim brought under the Dodd-Frank Act’s anti-retaliation provision, the district court’s denial of the defendant’s motion to dismiss is affirmed where, in using the term ‘whistleblower,’ Congress did not intend to limit protections to those who disclose information to the Securities and Exchange Commission. Rather, the anti-retaliation provision also protects those who were fired after making internal disclosures of alleged unlawful activity under the Sarbanes-Oxley Act and other laws, rules, and regulations.