Disparate treatment, evidence, policy & procedure, due process, private right of action.

A former employee of the American Standard Corporation appeals a lower court' ruling in his suit against the company. Officials at American Standard terminated Gerald Adler's employment, citing unsatisfactory work performance. Adler insisted the company terminated his employment because he alleged potentially illegal management activities. Adler subsequently filed suit, seeking compensatory and punitive damages. American Standard responded with a motion to dismiss.

A trial court granted American Standard's motion to dismiss the case. The court ruled Adler failed to adequately state his complaint. Adler now appeals.

Adler wins. The Maryland Court of Appeals reversed the