DiFiore v. CSL Behring, LLC –
3d Cir. – Jan. 3, 2018
Marie DiFiore asserted claims
against her former employer, CSL Behring, for retaliation in violation of the
False Claims Act, and for wrongful discharge under a theory of constructive
discharge in violation of Pennsylvania state law.
Held: An employee’s protected
activity must be the “but-for” cause of adverse actions to support a claim of
retaliation under the FCA.
