"Whistle-blowing" of actions of subordinates does not give rise to CEPA claim.

The plaintiff complained about the work performance and conduct of a number of his subordinates and recommended their discharge. The conduct complained of was not requested or sanctioned by the employer. In upholding the dismissal of the plaintiff's CEPA claim, the court held that complaints of conduct of subordinates over whom the plaintiff maintained supervision and control did not amount to "whistle-blowing" activity for purposes of the statute.

Case Law Alert - 1st Quarter 2013