On December 15, 2025, the California Court of Appeal, Fourth Appellate District, issued a published decision in Contreras v. Green Thumb Produce, Inc., reversing a trial court’s grant of judgment notwithstanding the verdict (JNOV) in favor of the employer defendant in a whistleblower retaliation and wrongful termination case. The decision provides significant guidance on the scope of California’s whistleblower protections under Labor Code section 1102.5(b), particularly as they apply to employees who act on reasonable but mistaken interpretations of the law.

Quick Hits

• The California Court of Appeal held that an employee’s reasonable, good-faith belief that an employer violated the law may support a whistleblower retaliation claim under California Labor Code section 1102.5(b), even if the employee’s legal interpretation is ultimately mistaken.
• The court emphasized that section 1102.5(b)’s “objective reasonableness” of the employee’s belief is a question of fact for the jury, not a matter of law for the court.
• The decision underscores that section 1102.5(b) is intended to encourage employees to report suspected legal violations without fear of retaliation, even if they lack legal training.

Background

The plaintiff, Manuel Contreras, a sanitation department employee, believed his employer was violating the California Equal Pay Act (EPA) by paying him less than coworkers performing similar duties. Contreras did not contend that his unequal wages were based on his sex,...

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