Lawson v. FMR LLC

134 S. Ct. 1158 (2014)

From our private database of 46,500+ case briefs, written and edited by humans—never with AI.

Lawson v. FMR LLC

United States Supreme Court
134 S. Ct. 1158 (2014)

  • Written by Heather Whittemore, JD

Facts

In 2002 Congress passed the Sarbanes-Oxley Act (the act) to prevent and punish corporate fraud. The act encouraged corporate employees to blow the whistle on wrongdoing by their employers and provided for whistleblower protections. Section 806 explicitly stated that the whistleblower protections forbade officers, employees, or contractors of public companies from discharging or otherwise discriminating against whistleblowers who were employees of publicly traded companies. Jackie Hosang Lawson and Jonathan M. Zang (plaintiffs) were employees of FMR LLC (defendant). FMR was a privately held company that contracted with publicly held companies to provide investment advice. Lawson and Zang were both fired after raising concerns about wrongdoing within FMR. Lawson and Zang filed lawsuits in federal court pursuant to § 806 of the act, seeking whistleblower protections. FMR filed motions to dismiss the cases, arguing that neither Lawson nor Zang had a claim for relief under § 806 because they were not employees of a publicly traded company. The district court denied FMR’s motions to dismiss. FMR appealed. The United States Court of Appeals for the First Circuit reversed the district court, holding that Lawson and Zang were not protected by § 806. The court of appeals reasoned that FMR was a contractor of a public company and was prohibited from discriminating against whistleblowers, but that Lawson and Zang were not among the protected class of employees. The United States Supreme Court granted certiorari.

Rule of Law

Issue

Holding and Reasoning (Ginsburg, J.)

Dissent (Sotomayor, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 832,000 law students since 2011. Some law schools even subscribe directly to Quimbee for all their law students.

  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.

Here's why 832,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 46,500 briefs, keyed to 994 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Access this case brief for FREE

With a 7-day free trial membership
Here's why 832,000 law students have relied on our case briefs:
  • Reliable - written by law professors and practitioners, not other law students
  • The right length and amount of information - includes the facts, issue, rule of law, holding and reasoning, and any concurrences and dissents
  • Access in your class - works on your mobile and tablet
  • 46,500 briefs - keyed to 994 casebooks
  • Uniform format for every case brief
  • Written in plain English - not in legalese and not just repeating the court's language
  • Massive library of related video lessons - and practice questions
  • Top-notch customer support

Access this case brief for FREE

With a 7-day free trial membership