ILCS » Chapter 20 · Act 415
Illinois Compiled Statutes

20 ILCS 415/19c.1 (2026)

(1) In any case involving any disclosure of information by an employee which the employee reasonably believes evidences-     (i) a violation of any law, rule, or regulation; or     (ii) mismanagement, a gross waste of funds, an abuse of authority, or a substantial and specific danger to public health or safety if the disclosure is not specifically prohibited by law, the identity of the employee may not be disclosed without the consent of the employee during any investigation of the information and any related matters

✓ current as of May 2026
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(20 ILCS 415/19c.1) (from Ch. 127, par. 63b119c.1)
    Sec. 19c.1. (1) In any case involving any disclosure of information by an employee which the employee reasonably believes evidences-
    (i) a violation of any law, rule, or regulation; or
    (ii) mismanagement, a gross waste of funds, an abuse of authority, or a substantial and specific danger to public health or safety if the disclosure is not specifically prohibited by law, the identity of the employee may not be disclosed without the consent of the employee during any investigation of the information and any related matters.
    (2) No disciplinary action shall be taken against any employee for the disclosure of any alleged prohibited activity under investigation or for any related activity. For the purposes of this Section, disciplinary action means any retaliatory action taken against an employee, including but not limited to reprimand, suspension, discharge, demotion or denial of promotion or transfer.
(Source: P.A. 85-470.)

    
Notes of Decisions
Cited in 11 cases (2 in the last 5 years), 1994–2022 · leading case: Metzger v. DaRosa, 805 N.E.2d 1165 (Ill. 2004).
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Metzger v. DaRosa, 805 N.E.2d 1165 (Ill. 2004). · cites it 12× “1 of the Illinois Personnel Code, 20 ILCS 415/19c.1, create an implied private right of action? 2.”
James Gooden v. Michael v. Neal, 17 F.3d 925 (7th Cir. 1994). “Defendants will have an uphill fight on this record, even with a properly instructed jury, but they are entitled to have the jury's decision on the factual questions rather than ours.”
Channon v. Westward Mgmt., Inc., 2022 IL 128040 (Ill. 2022). “¶ 21 In answering a certified question addressing whether an Illinois Personnel Code (20 ILCS 415/19c.1 (West 2002)) provision created an implied private right of action in Metzger, 209 Ill.”
Cretella v. Azcon, Inc., 2022 IL App (1st) 211224 (Ill. App. Ct. 2022). “The court ruled that implying a private right of action for state employees was not necessary to achieve the statutory purpose of encouraging honesty and candor among state employees because the Personnel Code expressly provided sufficient sanctions and remedies for violations…”
Davis v. Kewanee Hosp., 2014 IL App (2d) 130304 (Ill. App. Ct. 2014). “2d at 38 (the Personnel Code (20 ILCS 415/19c.1 (West 2002)) was designed primarily to benefit the general public by ensuring competent employees for government bodies).”
Carmichael v. Union Pac. R.R. Co., 2018 IL App (1st) 170075 (Ill. App. Ct. 2018). “Metzger, a state police employee, pursued a claim based on the state police's violation of the whistleblower protection provision of the Personnel Code ( 20 ILCS 415/19c.1 (West 2002) ). Metzger , 209 Ill.”
Metzger v. DaRosa (Ill. 2004). · cites it 9× “1 of the Illinois Personnel Code, 20 ILCS 415/19c.1, create an implied private right of action? 2.”
Metzger, Linette A. v. Darosa, Timothy (7th Cir. 2004). · cites it 3× “01-3093 & 01-3300 plaint against her employer and several individual defen- dants alleging, among other things, that her First Amendment rights had been violated by certain retaliatory acts (Count V) and that the defendants had violated her rights under the Illinois Whistle…”
Sutherland v. Norfolk S. Ry. Co. (Ill. App. Ct. 2005). · cites it 2× “1 of the Personnel Code (20 ILCS 415/19c.1 (West 2002)), which prohibited retaliation against state employees for reporting violations of " 'any law, rule, or regulation' " or " 'mismanagement, a gross waste of funds, an abuse of authority, or a substantial and specific danger…”
Wood v. Allied Interstate, LLC (N.D. Ill. 2018). “1 of the Illinois Personnel Code, 20 ILCS 415/19c.1, reasoning that because the Code “expressly provides sanctions and remedies for violations of its provisions,” its enforcement mechanisms were “sufficient to encourage the reporting of violations of the Personnel Code,” to…”
Bajalo v. Nw. Univ. (Ill. App. Ct. 2006). “1 of the Personnel Code (20 ILCS 415/19c.1 (West 2002)), which prohibited retaliation against state employees for reporting violations of “‘any law, rule, or regulation’” or “‘mismanagement, a gross waste of funds, and abuse of authority, or a substantial and specific danger to…”
— 20 ILCS 415/19c.1(2) — 2 cases
Metzger v. DaRosa, 805 N.E.2d 1165 (Ill. 2004). “1 of the Illinois Personnel Code, 20 ILCS 415/19c.1, create an implied private right of action? 2.”
Metzger v. DaRosa (Ill. 2004). “1 of the Illinois Personnel Code, 20 ILCS 415/19c.1, create an implied private right of action? 2.”
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