Competition Results

Wake Forest National Moot Court Team Wins Region and Best Brief, Sending them to the National Finals

From Left to Right: Blake Stafford ('17), Mia Falzarano ('17), and Matt Cloutier ('17)

From Left to Right: Blake Stafford (’17), Mia Falzarano (’17), and Matt Cloutier (’17)

On Saturday, November 19, the Wake Forest National Moot Court Team of Matt Cloutier (‘17), Mia Falzarano (’17), and Blake Stafford (’17) won the Region IV Tournament of the National Moot Court Competition, winning all five of their matches. The team also won the Best Brief award after its brief received an outstanding score of 97.25, nearly five points higher than the next best brief and far above the average score of 83.3. The Cloutier-Falzarano-Stafford team won both of Friday’s preliminary rounds, earning a spot in the elimination rounds. On Saturday, they beat out a team from Campbell in the quarterfinals, a team from William and Mary in the semi-finals, and a team from West Virginia in the final round.

The National Moot Court Competition is the country’s oldest interscholastic moot court tournament. Region IV, the largest region in the tournament, is open to law schools in Kentucky, North Carolina, Virginia, and West Virginia. This year there were 21 teams from 12 law schools, including Duke, George Mason and Virginia universities. The competition was held in the Fourth Circuit courthouse in Richmond, Virginia.

By winning the Region IV Tournament, the Wake Forest team earned a spot in the National Moot Court Finals, where the top two teams from all fifteen regions will compete in New York City in February. This is the fourth straight year in which Wake Forest has won the Region IV Tournament, and the third straight in which Wake Forest has won the regional Best Brief award.

The team is very grateful for all the support they received from numerous fellow students, alumni and other attorneys, faculty members who judged practice arguments. The practice round judges included Professors Eggert, Gokhale, Graham, Morrow, C. Rose, Verstein, Walker, and Wright; law school alumni Dylan Greenwood (’13), Pat Kane (’07), Kaitlin Price (’16), and Gordon Widenhouse (’81); and 3Ls Taylor Anderson, Nina Banfield, Kayleigh Butterfield, Drew Culler, Kyleigh Feehs, James Lathrop, Malorie Letcavage, Nicole Scallon, Daniel Stratton, and Paige Topper.

Alex Teixeira (JD ’18) Wins the 45th Annual Stanley Moot Court Competition

Stanley Finalists

Stanley Finalists Brooke Boutwell ’18 (left) & Alex Teixeira ’18 (right)

Alex Teixeira ’18 won the final round of the 45th annual Edwin M. Stanley Moot Court Competition held at Wake Forest School of Law on Friday, November 18, 2016. Teixeira represented fictional plaintiff, Sharon Weaver, arguing that the defendant, the Cumberland Cougars, owed a duty of care to protect spectators, like Ms. Weaver, from foul balls that enter the concession areas, in addition to the stands. Runner up finalist, Brooke Boutwell ’18 represented the fictional defendant, Appellee Cumberland Cougars, LLC, and contended that the District Court correctly predicted that Maryland would adopt the baseball rule. According to Boutwell, this rule, which required the defendant only to provide a screened area behind home plate, shields the defendant from liability.

Both Teixeira and Boutwell received high compliments from the three judges on the panel regarding their direct answering of questions, understanding of the case law, and overall presentation.

Several awards were given out after the finalists presented their arguments to the court. Texiera won the James C. Berkowitz Award for best oralist and Anna-Bryce Flow ’18 was the runner up. Kelsey Mellan ’18 won the award for best brief and Daniel McClurg ’18 was the runner up.

In addition to the finalists, the Moot Court Board is honored to welcome the following  students as new members to the Moot Court Board: Nick Bedo, Libby Casale, Michael Fleming, Anna-Bryce Flowe, John McCool, Kelsey Mellan, and John Allen Riggins. Congratulations to all the new members!

A special thank you to Erica Oates and Ethan White for an excellent job as the Stanley Competition co-chairs! The Stanley Moot Court Competition would not have been a success without your hard work and organization.

The Stanley Competition is an intramural moot court competition held each fall semester and open to all second and third-year law students. This competition is held in honor of Judge Edwin M. Stanley, a distinguished Wake Forest alumnus and supporter, who served as a United States District Court Judge for the Middle District of North Carolina from 1958 to 1968.

The summary of the case at issue is as follows:

Plaintiff Sharon Weaver is a resident of Clemmons, North Carolina, while Defendant Cumberland Cougars, LLC operates a minor league baseball team that plays its home games in Cougar Park in Cumberland, Maryland. 

Weaver attended a Cougars game on July 4, 2013, with her young children, her brother, and his young children.  They bought the “best available” seats online and were given seats behind home plate, which were protected from foul balls by a screen. Weaver had never been to Cougars Park.  She had attended several baseball games in the past and was aware that foul balls are sometimes hit into the stands. 

Before the game and during the third inning, an audio announcement, which was also projected on the scoreboard, warned fans to look out for balls and bats leaving the field of play.  After the seventh inning stretch, Weaver went to a concession stand on the third base side of the ballpark to buy drinks.  The concession stand was on a concourse behind the stands and placed so that people in line stood facing away from the field.  When Weaver was waiting in line, she sensed a stir in the crowd, turned to her left, and was hit by a foul ball. She suffered serious injuries. 

Weaver sued Defendant in the United States District Court for the District of Maryland.  The law of Maryland applies, including its negligence and assumption of the risk principles, but Maryland has not had a previous reported case involving foul balls.  The District Court granted Defendant’s motion for summary judgment based on the “Baseball Rule,” a limited duty rule providing that baseball ballpark operators owe no duty to protect spectators from foul balls other than providing a screened area behind home plate.  The Baseball Rule is a majority rule, but courts in some states have rejected it entirely or held that it applies only in the stands.  Weaver has appealed to the Fourth Circuit.

Mike Stephens ’18 Wins the 45th Annual Walker Moot Court Competition

walker final

The Honorable Richard Dietz ‘02, North Carolina Court of Appeals; Malcom Boyd ’18; Mike Stephens ’18; The Honorable Denise Hartsfield ‘91, Forsyth County District; and The Honorable Eric Morgan, Forsyth County Superior Court at the 45th Annual Walker Moot Court Competition at Wake Forest School of Law.

Mike Stephens ‘18 won the final round of the 45th annual George K. Walker Competition held at Wake Forest School of Law on Friday, April 15, 2016. Stephens represented fictional defendant, Deerfield Corrections, Inc., arguing that Deerfield’s policy of hiring only males as Boys Group Leaders at Skinner qualifies for the “bona fide occupational qualification” exception to Title VII’s prohibition against sex discrimination in employment based on concerns about the privacy and rehabilitation of the juveniles. Runner up finalist, Malcolm Boyd ‘18, represented fictional plaintiff, Paula Perez, a former Deerfield employee who was denied a Boys Group Leader position at Skinner because of her sex. See below for a full summary of the case.

judged the finals. The Moot Court Board would like to thank these distinguished judges for dedicating their time to support the Walker Moot Court Competition.

The judges each complimented Stephens and Boyd on their oral advocacy skills, knowledge of the record, and grasp of the law.

Several awards were give out after the finalists presented their arguments to the court. Distinctions for Best Brief, Best Oralist, and the Debbie Parker Memorial Moot Court Service Award were awarded.

Daniel McClurg won the Best Brief award and Mickey Herman was runner-up. The Best Oralist award went to John Van Swearingen and runner-up was Zachary McCamey.

The Debbie Parker Moot Court Service Award is an honor granted to either a member of the Moot Court Board or a participant in the Walker Moot Court Competition who exemplifies throughout the competition a spirit of dedication and service to Wake Forest University School of Law, as well as compassion and cooperation with his or her fellow students. This year the Debbie Parker Moot Court Service Award went to Lauren Emery ’16 and Eric Benedict ’17.

In addition to the finalists, the Moot Court Board is honored to welcome eighteen first-year students as new members: Ashley Barton, Malcolm Boyd, Mitchell Davis, Vanessa Garrido, Mickey Herman, Ryan Holt, Emily Lagan, David Layman, Zach McCamey, Daniel McClurg, Yawara Ng, Stephanie Poon, Emily Scotton, Mike Stephens, John Van Swearingen, Brittany Wages, Evan Weltge, and Zack Young. Congratulations to all the new members!

A special thank you to Eric Benedict and Kayla Fredrickson for an excellent job as this year’s competition chairpersons. The Walker Moot Court Competition would not have been a success without your hard work and organization!

For forty-five years, the Wake Forest Moot Court Board has conducted a moot court competition for first-year law students. In 1998, the Moot Court Board named this competition the George K. Walker Moot Court Competition in honor of Professor George Walker’s long-standing support of the Wake Forest Moot Court program. Thank you, Professor Walker, for your continued and unwavering support of Moot Court!

The summary of the case at issue is as follows:

Defendant Deerfield Corrections, Inc. is a private for-profit corporation that contracts with several states to operate correctional facilities. One of the facilities operated by Deerfield Corrections, Inc. is the Skinner Juvenile Detention Center in Forsyth County, North Carolina. Plaintiff Paula Perez was employed at Skinner from February 2012 to October 2015.  She started out as a third-shift Girls Group Leader and eventually moved up to second-shift Girls Group Leader. Ms. Perez received superior performance evaluations during her tenure as a Girls Group Leader. In February 2015, a first-shift Boys Group Leader position became open, and Ms. Perez applied. She was not hired for the position; Skinner’s Director of Human Resources, Ellie Herndon, informed her that pursuant to Deerfield Corrections’ policy, females could not serve as Boys Group Leaders at Skinner. Deerfield Corrections bases its policy on the belief that hiring only males to be Boys Group Leaders is necessary to enable it to achieve its mandate from the State to maintain a secure facility and to rehabilitate the juveniles while safeguarding their privacy rights. After being denied the Boys Group Leader position, Ms. Perez eventually quit her job at Skinner and later filed a charge of discrimination with the EEOC, which issued her a right-to-sue notice dated October 26, 2015.  Ms. Perez then filed this lawsuit against Deerfield Corrections, Inc.

The issue before the court is whether Deerfield’s policy of hiring only males as Boys Group Leaders at Skinner qualifies for the “bona fide occupational qualification” exception to Title VII’s prohibition against sex discrimination in employment based on concerns about the privacy and rehabilitation of the juveniles.

Two Wake Forest Teams compete at Billings, Exum and Frye Constitutional Law Competition

Evelyn Norton '16, Kelsey Kolb '16, and Emily Singer '16 at the Billings, Exum & Frye Constitutional Law competition at Elon University School of Law.

Evelyn Norton ’16, Kelsey Kolb ’16, Emily Singer ’16, and Professor Steve Garland at the Billings, Exum & Frye Constitutional Law competition at Elon University School of Law.

The Wake Forest Moot Court Board sent two teams of advocates to Elon University School of Law to compete in the Billings, Exum & Frye Constitutional Law Competition. The year marked the sixth annual  Moot Court Competition hosted at Elon University School of Law. The competition took place March 31-April 2, 2016.

The Billings, Exum & Frye Constitutional Law Competition honors three North Carolina Supreme Court Justices who have greatly impacted the Court: Rhona Bryan Billings, James G. Exum, and Henry E. Frye. The competition problem always focuses on constitutional law issues. This year twenty law schools, including Wake Forest, were represented at the competition

Steven Hemric '17, Cate Berenato '17, and Matthew Kerschner '17 at the Billings, Exum & Frye Constitutional Law competition at Elon University School of Law.

Steven Hemric ’17, Cate Berenato ’17, and Matthew Kerschner ’17 at the Billings, Exum & Frye Constitutional Law competition at Elon University School of Law.

 

One team was made up a three second year students: Steven Hemric ’17, Cate Berenato ’17, and Matthew Kerschner ’17. This team was coached by Professor John Korzen. The second team was made up of third year students: Evelyn Norton ’16, Kelsey Kolb ’16, and Emily Singer ’16. This team was by Professor Steve Garland. Both teams displayed impressive oral advocacy skills during the competition.

The teams would like to personally thank Professor John Korzen and Professor Steve Garland for lending their time and wisdom to the teams. Their dedication to the teams was expremely appreciated and help each team enter the competition fully prepared. The Wake Forest Moot Court Board and law school community is proud of the zealous advocacy skills of these six competitors!

 

Wake Forest Competes at the Gabrielli Family Law Competition

James Lathrop '17, Emily Jeske '17, and Katherine Haddock '17 at the Gabrielli Family Law Competition in Albany, New York.

James Lathrop ’17, Emily Jeske ’17, and Katherine Haddock ’17 at the Gabrielli Family Law Competition in Albany, New York.

James Lathrop ’17, Emily Jeske ’17, and Katherine Haddock ’17 represented the Wake Forest at the 28th Annual Gabrielli Family Law Competition at the Albany School of Law. The competition was held in Albany, New York from March 3 – March 6, 2016.

Wake Forest competed in five rounds and was ranked first after the preliminary rounds and first elimination round. The team ultimately finished among the top four out of twenty-one teams. The team finished as semifinalists. The Moot Court Board and Wake Forest Law community is proud of Lathrop, Jeske, and Haddock’s advocacy skills.

The team would like to thank all of the professors and deans who judged their practice rounds. They would especially like to thank Professor Graham who was an invaluable resource throughout the process. Congratulations on a great competition performance!

Jessup International Law Competition

Alan Bowie '16, Charley Conner '17, Alicha Grubb '16, Anastasia Fanning "16, and Cheslie  Kryst '16 at the Jessup International Law Competition in Washington D.C.

Alan Bowie ’16, Charley Conner ’17, Alicha Grubb ’16, Anastasia Fanning “16, and Cheslie Kryst ’16 at the Jessup International Law Competition in Washington D.C.

A team of five Wake Forest law students, Alicha Grubb ’16, Anastasia Fanning ’16, Alan Bowie ’16, Charley Connor ’17, and Cheslie Kryst ’16 competed in the Jessup International Law Competition. The competition was in Washington D.C. at George Washington University February 12-14th.

The team of advocates competed against eighteen other schools with nearly a hundred individual competitors. The problem considered relevant international law issues including cyber security, espionage, terrorism, and illegal detainment. The team worked hard all semester to research the complicated issues and craft cogent arguments.

The team put up a good fight but ended up 1-3. They notably defeated Johns Hopkins University, renowned for its International Law program. The team was narrowly defeated by Howard University and lost to finalists George Washington and George Mason University.

Cheslie Kryst placed in the top 30 oralists. The judges all complimented the team’s knowledge of the law and oral advocacy skills.
The team would like to personally thank all the professors who guest judged during their practice rounds. They would also especially like to thank their advisor, and coach Professor George Walker, the guru of all things international law. The Wake Forest Moot Court Board and law school community is very proud of the hard work and outstanding performance of this team of advocates!

 

 

Wake Forest National Moot Court Team Travels to New York City for Finals

Wake Forest School of Law’s National Moot Court Team traveled to New York City to compete in the National Moot Court Finals on February 9, 2016. The team included Lauren Emery (’16), Woody Angle (’16), and Kaitlin Price (’16). The team previously won the Region IV Tournament in November securing their spot at Finals.

The National Moot Court Competition is an annual inter-law school event co-sponsored by New York City Bar Association’s National Moot CourtCompetition Committee and the American College of Trial Lawyers.  Since 1950, the competition has promoted the appellate advocacy arts of intellectual rigor, legal research, and persuasive argument.  This historic competition allows student advocates to hone their appellate advocacy skills before prominent members of the legal profession.  Every year, over 120 law schools compete in regional rounds throughout the United States, with winners advancing to final rounds in New York City.

The top two teams from all fifteen regions nationwide traveled to New York City to compete. The competition was fierce and unfortunately Wake Forest’s team did not advance. However, the Moot Court board and the law school community is honored to have sent a National Moot Court team of three outstanding advocates to the National Moot Court Finals this year.

The team members want to thank their peers, professors, and coaches for their constant support and direction while preparing for Finals. Wake Forest Moot Court Board is proud of all the hard work Lauren Emery, Woody Angle, and Kaitlin Price put in to make their team a success!

Wake Forest Team Excels at Tulane Mardi Gras Sports Law Invitational Moot Court Competition

Sarah Remes ('17), Daniel Fowler ('17), and Blaydes Moore ('16)  outside the court house in New Orleans, Louisiana.

Sarah Remes (’17), Daniel Fowler (’17), and Blaydes Moore (’16) outside the court house in New Orleans, Louisiana.

Wake Forest Moot Court sent a team of advocates to New Orleans, Louisiana to compete in the Tulane Mardi Gras Sports Law Invitational Moot Court Competition on February 5-7. The team consisted of Daniel Fowler (’17), Blaydes Moore (’16), and Sarah Remes (’17). The competition was held at the U.S. District Court for the Eastern District of Louisiana.

Wake Forest’s team obtained multiple wins in the preliminary rounds. After a successful run, they faced a very difficult schedule going up against three of the eventual semi-finalists before being eliminated. The team would like to thank their coach and their peers who helped them practice and provided support.

The team would like to extend a special thank you to Professor Barbara Lentz who coached the team throughout their preparation. Thank you Daniel Fowler, Blaydes Moore, and Sarah Remes for putting in the hard work required for this competition. Wake Forest Moot Court Board is proud of your outstanding effort!

Wake Forest National Moot Court Team Wins Region IV Tournament in Richmond

Screen Shot 2015-11-23 at 3.18.49 PM

Woody Angle (’16}, Lauren Emery (’16), Kaitlin Price (’16), and Professor John Korzen in Richmond, Virginia after winning Regionals in the 2015 National Moot Court Competition.

On Saturday, November 21, the Wake Forest National Moot Court Team of Robert Angle (’16), Lauren Emery (’16), and Kaitlin Price (’16) won the Region IV Tournament, going 5-0 against five different law schools and finishing first out of twenty-one teams from twelve law schools.

The team also won the Best Brief Award after its brief received the highest score of the twenty-one briefs.

Price won the award for the best oralist, thereby earning the team every possible award given at the tournament.

The National Moot Court Region IV Tournament is open to law schools in Kentucky, North Carolina, Virginia, and West Virginia.  This year teams from the following law schools competed:  Campbell, Duke, Elon, George Mason, Kentucky, Louisville, North Carolina, Richmond, Wake Forest, Washington and Lee, West Virginia, and William and Mary.  The competition was held in the Fourth Circuit courthouse in Richmond, Virginia.

This year’s hypothetical problem involves a criminal prosecution for insider trading and is similar to a recent Second Circuit case, United States v. Newman.  The problem is set in the Supreme Court, with the Petitioner being the United States and the Defendant being Dana DiNofrio, a stockbroker who was convicted of insider trading before the Thirteenth Circuit reversed the conviction and ordered a new trial based both on the jury instructions and on excluded grand jury testimony of an unavailable witness.

In each match, a team’s oral argument score counts for 60% of the final score and its brief score counts for 40%.  The Angle-Emery-Price team won both of Friday’s preliminary rounds, earning a spot in the eight-team elimination rounds.  On Friday morning, Angle and Price argued for the Respondent and defeated a team from Elon, while in the afternoon Emery and Price argued on behalf of the Petitioner and defeated a team from Louisville that had the second-best brief score.  That round featured as “hot” a bench as one will ever encounter.  On Saturday morning, the team defeated a team from Campbell to reach the semi-finals and a team from University of North Carolina (which had the third-best brief score) to reach the finals.  In both of those Saturday morning rounds, Emery and Price argued for the Petitioner United States.

In the final round on Saturday afternoon, the team faced a Washington and Lee team, with Angle and Price arguing for the Respondent DiNofrio.  The four judges for the final round included two justices of the Virginia Supreme Court and two federal district court judges from Virginia.  They ruled that the Angle-Price team had won and that Price was the best oralist of the final round.

By winning the Region IV Tournament, the team earned a spot in the National Moot Court Finals, when the top two teams from all fifteen regions will compete in New York City on February 9-12.  This is the third straight year in which Wake Forest has won the Region IV Tournament, and the second straight in which Wake Forest has won the regional Best Brief award.

The other Wake Forest team, consisting of Josh Bussen (’16), Elizabeth Ruocco (’16), and Mackenzie Salenger (’16), also did well.  The team defeated a team from West Virginia on Friday morning before narrowly falling on Friday afternoon to the Washington and Lee team that finished second.

The teams are very grateful for all the support they received from numerous fellow students, alumni and other attorneys, and faculty members who judged practice arguments.  Student judges were Joey Greener (’16) and Alexis Iffert (’16).  Alumni and attorney judges were Jon Berkelhammer, Steve Berlin (’84), Nicole Dupre (’10), Randall Galyon (’96), Pat Kane (’07), Lorin Lapidus (’04), Steve Loew (’91), Luke Macdowall (’11), Caroline Massagee (’14), Zoe Niesel (’12), and Gordon Widenhouse (’81).  Several of the alumni judges were on the National Moot Court Team during their 3L year.  Faculty judges were Professor Emeritus Billings and Professors Garland, Gokhale, Graham, Lentz (twice), Lloyd, Mewhinney, Morrow, Palmiter, Peeples, Rabil, Verstein and Wright.  The teams’ advisors were Professor John Korzen and Professor Charles Rose.

Blake Stafford (’17) Wins the 44th Annual Stanley Moot Court Competition

Screen Shot 2015-11-23 at 3.25.30 PM

The 44th Annual Stanley Moot Court Competition finalists, Blake Stafford (’17) and Emily Jeske (’17), after presenting their oral arguments.

Blake Stafford (’17) won the final round of the 44th annual Stanley Moot Court Competition held at Wake Forest School of Law on November 20, 2015.

Stafford represented the fictional plaintiff Sarah Donaldson, arguing that her unsolicited internal complaints about a potential ERISA violated constituted protected conduct under ERISA’s whistleblower” or “anti-retaliation” provision, which makes it unlawful to discharge an employee who “has given information or testified or prepared to testify in any inquiry or proceeding” related to ERISA. Emily Jeske (’17) represented the fictional defendant St. Pete Medical Supply who argued that Ms. Donaldson did not engaged in protected conduct under ERISA. See below for a full summary of the case.

The judges were Richard Dietz (’02), judge on the N.C. Court of Appeals; Rhoda Billings (’66), a retired Wake Forest Law professor who was the first female chief justice of the North Carolina Supreme Court; and Ken Carlson (’90), an attorney at Constancy, Brooks, & Smith and a Wake Forest Law professor of Advanced Trial Practice and Trade Secrets and Unfair Competition. Both competitors did extremely well responding to questions from a hot bench. All three judges spoke very highly of both finalists and praised their oral advocacy skills. The judges noted that the final scores were extremely close decision.

Stafford also earned the award for best brief.

Stafford was not the only student to take home an award. Mia Falzarano (’17) was named best oralist and the winner of the James C. Berkowitz Award, which was presented by the Berkowitz family. This year marks the 31th anniversary of the death of James, who was in a car accident while returning to the law school to argue in the quarterfinals of the 1984 Stanley Competition.

As a result of their performance in this competition, we welcome ten new members to the Moot Court Board: Ryan Bowersox, Maria Collins, Christopher Conley, Casey Fidler, Wes Harty, Alanna Jereb, James Lathrop, Amelia Lowe, Erica Oats, and Daniel Stratton.

A special thank you to Katie Law (’16) and Ben Leighton (’16) to the 2015 Stanley Competition Co-Chairs who did a great job running the competition. This competition would not have been a success without your hard work!

The intramural moot court competition is named in honor of the late Judge Edwin M. Stanley, a distinguished Wake Forest alumnus and supporter, who served as a U.S. District Court Judge for the Middle District of North Carolina from 1958-1968.

A summary of the case is set forth below:

This appeal involves the interpretation of a “whistleblower” or “anti-retaliation” statute, section 510 of the Employer Retirement Income Security Act of 1974 (ERISA), codified at 29 U.S.C. § 1140. The issue is whether Plaintiff Sarah Donaldson engaged in conduct protected by section 510, which makes it unlawful to discharge an employee who “has given information or testified or prepared to testify in any inquiry or proceeding” related to ERISA.

Donaldson was the Human Resources Director for Defendant St. Pete Medical Supply, Inc. She also served on St. Pete’s five-member pension committee, which met twice per year and decided where to invest employee pension contributions. At the committee’s September 2013 meeting, the committee voted 3-2 to invest in a relatively new company, Sunshine State Investment Professionals, which was owned by the brother of St. Pete’s Treasurer, Karl Wagner.

After the meeting, Donaldson met twice with Wagner to express concern that the investment with Sunshine State might violate ERISA. Wagner dismissed her concerns and said she could bring them up again at the next pension committee meeting, in late March 2014. In December 2013, Donaldson emailed St. Pete’s President Thomas Sinclair and left him a voicemail, noting her concerns and asking to meet with him. Sinclair never responded to Donaldson and told Wagner that he had heard from Donaldson but had complete confidence in Wagner.

Donaldson left Sinclair a similar voicemail in January 2014, again with no response.  On March 1, 2014, Sinclair told Donaldson she had been fired because the company wanted to “go in another direction.” St. Pete also gave three specific reasons for firing her, but they are disputed and not part of this appeal. The Middle District of Florida granted St. Pete’s motion for summary judgment, holding that the statute did not protect Donaldson’s conduct. She has appealed to the Eleventh Circuit. The parties disagree over whether section 510 protects an employee’s unsolicited internal complaint to management and base their arguments on the plain meaning of section 510, other circuit decisions on point, and interpretation of other whistleblower statutes.