Temporal proximity, without more, is insufficient to sustain CEPA claim.

The plaintiff was terminated as a sales executive, and he asserted that it was in retaliation for objecting to his employer’s alleged failure to meet regulatory requirements. In affirming the dismissal of the claim, the unanimous Appellate Division panel concluded that the plaintiff’s only evidence was of the temporal proximity between his objection and the termination decision and that this, standing alone, was insufficient.

Case Law Alert, 1^st Quarter 2014