Lawson v. FMR LLC
134 S. Ct. 1158
| SCOTUS | 2014Background
- Case involves whistleblower protections under Sarbanes–Oxley §1514A for employees of private contractors serving public funds; plaintiffs Lawson and Zang worked for private firms contracted to Fidelity mutual funds (public companies) and alleged retaliation for whistleblowing; district court denied dismissal; First Circuit held §1514A barred only a narrow reading covering public company employees; Supreme Court reversed, holding contractor employees are protected; decision addresses relationship to AIR 21 and Dodd–Frank; case ultimately remanded for proceedings consistent with Court’s opinion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does §1514A(a) protect contractor employees? | Lawson argues yes; contractors are protected. | FMR argues no; protection limited to public-company employees. | Yes, contractor employees protected. |
| Should statutory headings/context limit reach of §1514A? | Heading/context support broad protection. | Headings/context limit to public-company employees. | Headings/context do not constrain reach; broader reading adopted. |
| Should ARB Spinner interpretation receive deference? | ARB interpretation correct to extend coverage. | Chevron/Mead deference to agency; not applicable. | ARB interpretation not controlling; Court adopts its own textual reading. |
Key Cases Cited
- Moskal v. United States, 498 U.S. 103 (1990) (interpretation based on ordinary meaning of statutory text)
- Trainmen v. Baltimore & Ohio R. Co., 331 U.S. 519 (1947) (headings not to replace detailed text; general subject matter)
- United States v. Mead Corp., 533 U.S. 218 (2001) (limits on agency deference; not applicable here)
- Griffin v. Oceanic Contractors, Inc., 458 U.S. 564 (1982) (absurd-results-avoidance principle in statutory interpretation)