English v. General Electric Co.

Vera English (plaintiff), a nuclear-facility lab technician, reported safety violations to management and regulators, then deliberately left a contaminated table uncleaned to draw attention to the problem, after which General Electric (GE) (defendant) fired her; her federal whistleblower retaliation complaint was dismissed as untimely, and her later state-court IIED and wrongful-termination suit was found preempted by the district court based on three features of the federal Energy Reorganization Act (ERA): its non-protection of deliberate violators, its lack of punitive damages, and its strict 30-day filing deadline. The Fourth Circuit affirmed the preemption ruling.