NAHOOM
v.
FLORIDA LEAGUE OF CITIES INCORPORATED
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A plaintiff claiming private whistleblower protection under section 448.102(3), Florida Statutes, must allege an actual violation of a law, rule, or regulation, not just a suspected violation, to survive summary judgment.
[1] To establish a prima facie case of whistleblower retaliation under section 448.102, Florida Statutes, a plaintiff must demonstrate disclosure of an actual violation of la…
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Join FLexlaw to unlock all legal intelligence“An employer may not take any retaliatory personnel action against an employee because the employee has: (1) Disclosed, or threatened to disclose, to any appropriate governmental agency, under oath, in writing, an activity, policy, or practice of the employer that is in violation of a law, rule, or regulation.”
Statutory language from section 448.102(1), Florida Statutes, cited to support the requirement of actual violation
Michael Nahoom appealed a summary judgment granted in favor of the Florida League of Cities. The case involved whether Nahoom had established a valid …
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March 5, 2025 PER CURIAM.
AFFIRMED. Gessner v. Southern Co., 396 So. 3d 908 (Fla. 1st DCA 2024) (holding that a plaintiff claiming private whistleblower protection under section 448.102(3), Florida Statutes, must allege an actual violation of a law, rule, or regulation, not just a “suspected violation,” in order to survive summary judgment); see also § 448.102(1), Fla. Stat. (“An employer may not take any retaliatory personnel action against an employee because the employee has: (1) Disclosed, or threatened to disclose, to any appropriate governmental agency, under oath, in writing, an activity, policy, or practice of the employer that is in violation of a law, rule, or regulation.” (emphasis supplied)); Washington v. Florida Dept. of Revenue, 337 So. 3d 502, 509 (Fla. 1st DCA 2022) (“To establish a prima facie case under the Whistle-blower’s Act, a plaintiff must show that (1) prior to his or her termination, he or she made a disclosure protected by the Act . . . .” (emphasis supplied)). ROWE, WINOKUR, and NORDBY, JJ., concur.
_____________________________ Not final until disposition of any timely and authorized motion under Fla. R. App. P. 9.330 or 9.331.
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Nahoom v. Fla. League of Cities Inc., 396 So. 3d 908 (Fla. 1st DCA 2025)…reatened to disclose, to any appropriate governmental agency, under oath, in writing, an activity, policy, or practice of the employer that is in violation of a law, rule, or regulation.” (emphasis supplied)); Washington v. Florida Dept. of Revenue, 337 So. 3d 502, 509 (Fla. 1st DCA 2022) (“To establish a prima facie case under the Whistle-blower’s Act, a plaintiff must show that (1) prior to his or her termination, he or she made a disclosure protected by the Act . . . .” (emphasis supplied)). ROWE, WINOKUR,…1 / 2
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Mamadou Ouedraogo v. Walmart Stores E., LP (Fla. 1st DCA 2026)…ng so would have required them to turn their heads at > least 90 degrees. The fact that the banana peel was on the > floor for just under 8 minutes, is irrelevant. This appeal followed. We review the trial court's order de novo. Gessner v. S. Co., 396 So. 3d 908, 910 (Fla. 1st DCA 2024). The federal summary judgment standard, which Florida has adopted, requires that a trial court grant summary judgment if the movant "shows that there is no genuine dispute as to any material fact and the movant is entitled t…
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Gessner v. S. Co. (Fla. 2026)
Previewing 3 of 4 citing cases — full citator treatment, depth of discussion, and citing context are member features.
Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- Washington v. Fla. Dep't of Revenue, 337 So. 3d 502 (Fla. 1st DCA 2022)
- Nahoom v. Fla. League of Cities Inc., 396 So. 3d 908 (Fla. 1st DCA 2025)