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Fourth Circuit Limits Scope of ERISA Anti-Retaliation Statute
Winston-Salem Journal 
[Opinion] Sept. 6, 2012
"While ERISA protects employees who report wrongdoings by their employers across most of the country, folks in the 2nd, 3rd and 4th federal court circuits are not protected when they report issues 'internally' -- that means to their employers. Folks in all the other federal circuits are protected.... [T]he only way to now fix the problem is to amend ERISA so that it clearly protects people who file what are called 'internal reports'; that is, when a person files a report or sends an email to his or her supervisor or executive management that says, 'Hey, I think we have a problem here'."
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