Lawson v. Bowie State Univ., 2011 Md. LEXIS 515 (Md. Aug. 16, 2011).

A state employee wrote a letter disclosing potential abuses in the defendant university’s police department. The employee sent the letter to the university’s vice president, after which the vice president notified the Chief of the University Police Department about the information in the letter. The Chief then fired the employee. The former employee then filed a complaint under Maryland Whistleblower’s Act. The complaint was denied, and an administrative law judge affirmed the denial. The Circuit Court for Prince George’s County affirmed the denial, holding that whistleblower protections did not extend to employees who disclosed possible violations due to personal motivations to make changes in the department. The Court of Appeals reversed, holding that the statute requires only that an employee have a reasonable belief that the information disclosed evidences a violation, but not that the employee possess a purely altruistic motive for the disclosure.