California Court: Broad 1102.5 Protection Doesn't Bar Summary Judgment Where Years of Performance Issues Exist
In Han v. Pfizer, the Northern District of California granted summary judgment for the employer despite protected whistleblowing, emphasizing that years of documented performance deficiencies can defeat a Section 1102.5 retaliation claim. The ruling reaffirms the broad construction of protected activity but underscores the decisive value of contemporaneous performance records.