Dept. of Public Health v. Estrada

Summary

The court held that the Commission on Human Rights and Opportunities had subject matter jurisdiction over the employee’s whistleblower-retaliation complaint even though she had separately grieved the same personnel actions, because her grievances did not assert whistleblower retaliation. It further held that the whistleblower statute protects an employee who reports the employee’s own error, but the employee must prove that discipline resulted from the disclosure rather than the underlying misconduct. Because the employee showed no retaliatory motive beyond temporal proximity and the department established legitimate performance-based reasons for its actions, the court affirmed the judgment for the department.