Texas Department of Transportation v. Needham

In this Texas Whistleblower Act suit we determine whether the Texas Department of Transportation is an appropriate law enforcement authority to which a public employee may report an alleged driving while intoxicated incident. If TxDOT is not, we must determine whether the public employee had a good faith belief that it was an appropriate law enforcement authority. The trial court rendered judgment based on the jury’s verdict for Eddie Needham, TxDOT’s former employee who TxDOT allegedly retaliated against because he reported a co-worker’s alleged unlawful conduct to TxDOT supervisors. The court of appeals affirmed the trial court’s judgment. __ S.W.3d __.

We conclude, under the circumstances in this case, that TxDOT was not an appropriate law enforcement authority as the Whistleblower Act defines that term. We also conclude that there is no evidence to support a finding that Needham had a good faith belief that TxDOT was an appropriate law enforcement authority. Accordingly, we reverse the court of appeals’ judgment and render judgment that Needham take nothing.