Edwards v. A.H. Cornell and Son, Inc.

Shirley Edwards (plaintiff) worked for A. H. Cornell and Son, Inc. (A. H. Cornell) (defendant). Edwards believed that A. H. Cornell engaged in practices that violated the Employee Retirement Income Security Act (ERISA), such as lying about the cost of benefit plans so that employees would not enroll in the group health plan and submitting fake Social Security numbers and other false information to insurance companies in enrolling noncitizens. Edwards asserted that she voluntarily reported her concerns to A. H. Cornell and was fired. Edwards sued A. H. Cornell and two supervisors (defendants), claiming that her termination was in violation of ERISA’s antiretaliation provision. A. H. Cornell and the supervisors moved for dismissal, which a district court granted. ERISA’s provision against retaliation made it illegal to terminate an employee for providing information in connection with an inquiry or a proceeding. Black’s Law Dictionary defined an inquiry as a solicitation for information and a proceeding as the forward progression of a legal complaint or the process related to seeking a remedy from an agency or a tribunal. The district court determined that Edwards’s voluntary disclosure of her complaint to her employer was not connected to an inquiry or to a proceeding, and her statements were not covered as a protected activity by ERISA’s sanction against retaliation. Edwards appealed and argued for a broader interpretation of the statute.