Darshana Indira and Trisha Gautam Publish Law360 Article Covering Massachusetts Whistleblower Protections
Darshana Indira and Trisha Gautam recently published an article in Law360 analyzing the Massachusetts Supreme Judicial Court’s recent decision in Galvin v. Roxbury Community College and its implications for employers under the Massachusetts Whistleblower Act.
In the article, titled “What Mass. Ruling Clarifies About Whistleblower Protections,” Indira and Gautam examine the court’s decision, addressing whether employees whose job duties include monitoring and ensuring compliance can claim whistleblower protection when the alleged violation falls within their own responsibilities.
The court answered the question decisively: an employee does not lose whistleblower protection simply because identifying or reporting the violation was part of the employee’s role.
This case involved Thomas Galvin, who served as the director of facilities and public safety at Roxbury Community College and was responsible for campus security and compliance with the Clery Act. After learning of unreported sexual assault allegations that should have been included in the college’s federal disclosures, Galvin raised concerns internally and with the Massachusetts State Auditor’s Office. His employment was subsequently terminated, and a jury found that his whistleblowing was the determinative cause of his termination.
Indira and Gautam explain that the court’s reasoning reinforces the broad scope of the Whistleblower Act. The statute contains no limitation excluding employees who are involved in or responsible for the conduct at issue, and the court recognized that compliance officers and similar roles are often the individuals most likely to identify regulatory failures. Excluding them from protection would undermine the statute’s purpose of encouraging the reporting of violations that might otherwise remain concealed.
At the same time, the article notes an equally important distinction drawn by the court: establishing that an employee engaged in protected activity does not resolve whether the employee was unlawfully terminated. Employers retain the ability to address performance issues and misconduct, including failures related to compliance. The critical question is whether the adverse action was taken because of the employee’s protected activity—a fact-intensive determination properly left to the jury.
The article offers practical takeaways for employers, including how important it is to maintain thorough documentation of performance evaluations and disciplinary decisions, ensuring that employees have accessible internal channels for raising concerns, and applying disciplinary policies consistently. There is a particular emphasis that employers who invest in strong compliance programs and approach disciplinary decisions with care will be better positioned to navigate scrutiny when compliance failures come to light through internal reporting.
The full article is available to subscribers at Law360.
