Joseph Peine v. HIT Services L.P., Wood Group USA, Inc., John Wood Group PLC, Wood Group Power GP, LLC and Wood Group Management Services, Inc., 479 S.W.3d 445

Peine was HIT Services’ CFO and secretary of Wood Group Power GP, LLC, with reporting to multiple supervisors.
Kumar allegedly ordered Peine to inflate HIT Services’ profits by about $2.5 million and falsify records, which Peine refused as improper.
Peine reported Kumar’s conduct to supervisors who sought to fix the accounting, including authorizing adjustments and a corrective end-of-year action.
Peine subsequently disclosed confidential HIT Services documents to a Thomson Reuters reporter, admitting he sent the materials.
An internal audit was initiated; Abby Yates, an in-house attorney, recommended Peine be placed on paid leave and that Kumar be removed from his accounting role during the investigation.
Peine was terminated on September 16, 2009 for breaching confidentiality obligations; he sued alleging wrongful discharge under Sabine Pilot for refusing to commit an illegal act.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Peine was terminated solely for refusing to commit an illegal act	Peine argues sole-cause liability under Sabine Pilot	Defendants contend there was a legitimate non-illegal-act reason (breach of confidentiality)	No; termination had a legitimate reason beyond refusal to act illegally
Whether the termination evidence shows direct evidence or circumstantial evidence of sole-cause	Peine claims direct evidence through internal communications	Record shows circumstantial evidence; speakers’ roles in firing are not shown	Evidence is circumstantial and does not raise a genuine issue on sole-cause

Sabine Pilot Serv., Inc. v. Hauck, 687 S.W.2d 733 (Tex. 1985) (sets the sole-cause standard for illegal-act termination claims)
Casarez v. K-G Pizza, 937 S.W.2d 444 (Tex. 1996) (discusses causation standards in workers’ compensation retaliation context)
Winters v. Houston Chronicle Publ’g Co., 795 S.W.2d 723 (Tex. 1990) (public policy limits Sabine Pilot extensions; reporting illegal activity not protected under Sabine Pilot)
Hawthorne v. Star Enterprise, Inc., 45 S.W.3d 757 (Tex. App.—Texarkana 2001) (distinguishes Hawthorne from Sabine Pilot extension; standing order context)
Marx v. Electronic Data Sys. Corp., 418 S.W.3d 626 (Tex. App.—Amarillo 2009) (causal inferences in retaliation contexts; timing alone may be insufficient)
Austin v. HealthTrust, Inc., 967 S.W.2d 400 (Tex. 1998) (limits recognized whistleblower protections; Sabine Pilot not extended by public policy)