Court upholds summary disposition against woman alleging Whistleblower Protection Act violation, refusing to apply WPA to contract renewal

The Plaintiff was improperly suspended in October of 2013 by the MGH Family Health Center, after engaging in protected activity.  She was notified two weeks later that her annual contract would not be renewed on January 1 of 2014.  She filed a lawsuit on February 19 of that year, arguing that she was wrongfully terminated for engaging in protected activity.  The trial judge summarily dismissed her claim, holding that while the Whistleblower Protection Act applies to preclude termination of employment, it does not protect an employee's right to contract renewal.  The judge also held that her 90 day limit on filing suit commenced when she was notified of the suspension--and that no new violation or time limit resulted from the notice of non-renewal.  With that interpretation, her February lawsuit was not filed within the 90-day limit.

The Court of Appeals affirmed the lower court's holding and its analysis.  It held that Plaintiff Bradford's rights under the WPA were limited to acting within 90 days of her wrongful suspension, and that she had no WPA rights arising out of the non-renewal.