Ohio Revised Code

Ohio Rev. Code § 4113.52 (2026)

Reporting violations by state and local officials and employees

✓ current as of May 2026
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(A)(1)(a) All state officials and employees employed by or appointed to a state agency as defined in division (D) of section 121.41 of the Revised Code shall report alleged fraud, theft in office, or the misuse or misappropriation of public money by a state official or employee to the inspector general. All other state employees and elected officials shall report fraud, theft in office, or the misuse or misappropriation of public money to the auditor of state's fraud-reporting system under section 117.103 of the Revised Code.

(b) A person is required to make a report under division (A)(1)(c) of this section if the person meets any of the following:

(i) The person is elected to local public office.

(ii) The person is appointed to or within a local public office.

(iii) The person has a fiduciary duty to a local public office.

(iv) The person holds a supervisory position within a local public office.

(v) The person is employed in the department or office responsible for processing any revenue or expenses of the local public office.

(c) If a person identified in division (A)(1)(b) of this section, during the person's term of office or in the course of the person's employment, becomes aware of fraud, theft in office, or the misuse or misappropriation of public money, the person shall timely notify the auditor of state via the auditor of state's fraud-reporting system under section 117.103 of the Revised Code or via other means.

(d) A person who serves as legal counsel, or who is employed as legal counsel, for a local public office or a state official or employee employed by or appointed to a state agency is not required to make a report under division (A)(1)(a) or (c) of this section concerning any communication received from a client in an attorney-client relationship.

(e) Divisions (A)(1)(a), (b), and (c) of this section do not apply to a prosecuting attorney, director of law, village solicitor, or similar chief legal officer of a municipal corporation, or to any employee of the prosecuting attorney, director of law, village solicitor, or similar chief legal officer of a municipal corporation.

(f) If a person becomes aware in the course of the person's employment of a violation of any state or federal statute or any ordinance or regulation of a political subdivision that the person's employer has authority to correct, and the person reasonably believes that the violation is a criminal offense that is likely to cause an imminent risk of physical harm to persons or a hazard to public health or safety, a felony, or an improper solicitation for a contribution, the person orally shall notify the person's supervisor or other responsible officer of the person's employer of the violation and subsequently shall file with that supervisor or officer a written report that provides sufficient detail to identify and describe the violation. If the employer does not correct the violation or make a reasonable and good faith effort to correct the violation within twenty-four hours after the oral notification or the receipt of the report, whichever is earlier, the person may file a written report that provides sufficient detail to identify and describe the violation with the prosecuting authority of the county or municipal corporation where the violation occurred, with a peace officer, with the inspector general if the violation is within the inspector general's jurisdiction, with the auditor of state's fraud-reporting system under section 117.103 of the Revised Code if applicable, or with any other appropriate public official or agency that has regulatory authority over the employer and the industry, trade, or business in which the employer is engaged.

(g) If a person makes a report under division (A)(1)(f) of this section, the employer, within twenty-four hours after the oral notification was made or the report was received or by the close of business on the next regular business day following the day on which the oral notification was made or the report was received, whichever is later, shall notify the person, in writing, of any effort of the employer to correct the alleged violation or hazard or of the absence of the alleged violation or hazard.

(2) If a person becomes aware in the course of the person's employment of a violation of Chapter 3704., 3734., 6109., or 6111. of the Revised Code that is a criminal offense, the person directly may notify, either orally or in writing, any appropriate public official or agency that has regulatory authority over the employer and the industry, trade, or business in which the employer is engaged.

(3) If a person becomes aware in the course of the person's employment of a violation by a fellow employee of any state or federal statute, any ordinance or regulation of a political subdivision, or any work rule or company policy of the person's employer and the person reasonably believes that the violation is a criminal offense that is likely to cause an imminent risk of physical harm to persons or a hazard to public health or safety, a felony, or an improper solicitation for a contribution, the person orally shall notify the person's supervisor or other responsible officer of the person's employer of the violation and subsequently shall file with that supervisor or officer a written report that provides sufficient detail to identify and describe the violation.

(4) The reporting requirements under division (A) of this section are not intended to infringe, and should not be interpreted as infringing on, the constitutional right against self-incrimination.

(B) Except as otherwise provided in division (C) of this section, no employer shall take any disciplinary or retaliatory action against an person for making any report authorized by division (A)(1) or (2) of this section, or as a result of the person's having made any inquiry or taken any other action to ensure the accuracy of any information reported under either such division. No employer shall take any disciplinary or retaliatory action against a person for making any report authorized by division (A)(3) of this section if the person made a reasonable and good faith effort to determine the accuracy of any information so reported, or as a result of the person's having made any inquiry or taken any other action to ensure the accuracy of any information reported under that division. For purposes of this division, disciplinary or retaliatory action by the employer includes, without limitation, doing any of the following:

(1) Removing or suspending the person from employment;

(2) Withholding from the person salary increases or employee benefits to which the person is otherwise entitled;

(3) Transferring or reassigning the person;

(4) Denying the person a promotion that otherwise would have been received;

(5) Reducing the person in pay or position.

(C) A person shall make a reasonable and good faith effort to determine the accuracy of any information reported under division (A)(1) or (2) of this section. If the person who makes a report under either division fails to make such an effort, the person may be subject to disciplinary action by the person's employer, including suspension or removal, for reporting information without a reasonable basis to do so under division (A)(1) or (2) of this section.

(D) If an employer takes any disciplinary or retaliatory action against an person as a result of the person's having filed a report under division (A) of this section, the person may bring a civil action for appropriate injunctive relief or for the remedies set forth in division (E) of this section, or both, within one hundred eighty days after the date the disciplinary or retaliatory action was taken, in a court of common pleas in accordance with the Rules of Civil Procedure. A civil action under this division is not available to a person as a remedy for any disciplinary or retaliatory action taken by an appointing authority against the person as a result of the person's having filed a report under division (A) of section 124.341 of the Revised Code.

(E) The court, in rendering a judgment for the person in an action brought pursuant to division (D) of this section, may order, as it determines appropriate, reinstatement of the person to the same position that the person held at the time of the disciplinary or retaliatory action and at the same site of employment or to a comparable position at that site, the payment of back wages, full reinstatement of fringe benefits and seniority rights, or any combination of these remedies. The court also may award the prevailing party all or a portion of the costs of litigation and, if the person who brought the action prevails in the action, may award the prevailing person reasonable attorney's fees, witness fees, and fees for experts who testify at trial, in an amount the court determines appropriate. If the court determines that an employer deliberately has violated division (B) of this section, the court, in making an award of back pay, may include interest at the rate specified in section 1343.03 of the Revised Code.

(F) Any report filed with the inspector general under this section shall be filed as a complaint in accordance with section 121.46 of the Revised Code.

(G) As used in this section:

(1) "Contribution" has the same meaning as in section 3517.01 of the Revised Code.

(2) "Improper solicitation for a contribution" means a solicitation for a contribution that satisfies all of the following:

(a) The solicitation violates division (B), (C), or (D) of section 3517.092 of the Revised Code;

(b) The solicitation is made in person by a public official or by an employee who has a supervisory role within the public office;

(c) The public official or employee knowingly made the solicitation, and the solicitation violates division (B), (C), or (D) of section 3517.092 of the Revised Code;

(d) The employee reporting the solicitation is an employee of the same public office as the public official or the employee with the supervisory role who is making the solicitation.

(3) "Misappropriation of public money" means knowingly using public money or public property for an unauthorized, improper, or unlawful purpose to serve a private or personal benefit or interest.

(4) "Misuse of public money" means knowingly using public money or public property in a manner not authorized by law.

(5) "Public office" has the same meaning as in section 117.01 of the Revised Code.

(H) Nothing in this section shall be construed to limit the authority of an auditor to make inquiries or interview state or local government employees or officials or otherwise perform audit procedures related to fraud during the course of an audit or attestation engagement.

Last updated January 17, 2024 at 5:29 PM

Notes of Decisions
Cited in 180 cases (37 in the last 5 years), 1990–2026 · leading case: Kulch v. Structural Fibers, Inc., 677 N.E.2d 308 (Ohio 1997).
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Kulch v. Structural Fibers, Inc., 677 N.E.2d 308 (Ohio 1997). · cites it 166× “The first is whether the court of appeals erred in finding that appellees were entitled to summary judgment on Kulch’s statutory cause of action for violations of R.C. 4113.52, Ohio’s Whistleblower Statute.”
Kulch v. Structural Fibers, Inc., 1997 Ohio 219 (Ohio 1997). · cites it 179× “] Employment relations—At-will employee discharged or disciplined for filing complaint with OSHA is entitled to maintain common-law tort action against employer for wrongful discharge/discipline in violation of public policy—R.C. 4113.52, construed. __________________ 1.”
Pytlinski v. Brocar Prods., Inc., 760 N.E.2d 385 (Ohio 2002). · cites it 35× “Appellees argued that Pytlinski’s complaint was time-barred by the one-hundred-eighty-day limitations period set forth in R.C. 4113.52, the Ohio Whistleblower Act.”
Contreras v. Ferro Corp., 652 N.E.2d 940 (Ohio 1995). · cites it 35× “The first is whether the court of appeals erred in finding that appellees were entitled to summary judgment on Contreras’s claim for violations of R.C. 4113.52, Ohio’s Whistleblower Statute.”
Pytlinski v. Brocar Prod., Inc., 2002 Ohio 66 (Ohio 2002). · cites it 37× “Appellees argued that Pytlinski’s complaint was time-barred by the one-hundred-eighty-day limitations period set forth in R.C. 4113.52, the Ohio Whistleblower Act.”
Celeste v. Wiseco Piston, 784 N.E.2d 1198 (Ohio Ct. App. 2003). · cites it 28× “52 and appellant’s failure to allege that he complied with the written notice requirements of the statute.”
Ehrlich v. Kovack, 135 F. Supp. 3d 638 (N.D. Ohio 2015). · cites it 55× “Specifically, Defendants assert-the whistleblower statute relied on by Plaintiff, Ohio Rev.Code § 4113.52, pro *650 vides protection for private sector employees who report information about their employer.”
Dobrski v. Ford Motor Co., 698 F. Supp. 2d 966 (N.D. Ohio 2010). · cites it 46× “) Although it is unclear in the Complaint what legal theory Dobrski relies upon to support this claim, his briefing clarifies that he is asserting a claim for wrongful discharge in violation of public policy under Ohio law.”
Poluse v. City of Youngstown, 735 N.E.2d 505 (Ohio Ct. App. 1999). · cites it 24× “Appellant initiated this action below under R.C. 4113.52, Ohio’s Whistleblower Statute.”
Lee v. Cardington (Slip Opinion), 2014 Ohio 5458 (Ohio 2014). · cites it 42× “] Employment relations—R.C. 4113.52—Whistleblower protection—Reporting of employer’s criminal violations—Standards that must be met to qualify for protection.”
Hulsmeyer v. Hospice of Sw. Ohio, Inc. (Slip Opinion), 2014 Ohio 5511 (Ohio 2014). · cites it 10× “24, Hulsmeyer could have reported any reasonable suspicion of abuse or neglect to her employer pursuant to Ohio’s Whistleblower Statute, R.C. 4113.52. Review of Hulsmeyer’s complaint, however, demonstrates the inapplicability of that statute.”
Shingler v. Provider Servs. Holdings, L.L.C., 2018 Ohio 2740 (Ohio Ct. App. 2018). · cites it 14× “Shingler asserts that because she failed to comply with the requirements for bringing a wrongful discharge claim under Ohio’s whistleblower statute, R.C. 4113.52, she has no adequate statutory remedy and is, therefore, entitled, as a matter of law, to bring a common-law claim…”
Show all 180 citing cases →
— Ohio Rev. Code § 4113.52(3) — 1 case
Hale v. Mercy Health Partners, 20 F. Supp. 3d 620 (S.D. Ohio 2014).
— Ohio Rev. Code § 4113.52(A) — 16 cases
Kulch v. Structural Fibers, Inc., 677 N.E.2d 308 (Ohio 1997). “The first is whether the court of appeals erred in finding that appellees were entitled to summary judgment on Kulch’s statutory cause of action for violations of R.C. 4113.52, Ohio’s Whistleblower Statute.”
Hulsmeyer v. Hospice of Sw. Ohio, Inc. (Slip Opinion), 2014 Ohio 5511 (Ohio 2014). “24, Hulsmeyer could have reported any reasonable suspicion of abuse or neglect to her employer pursuant to Ohio’s Whistleblower Statute, R.C. 4113.52. Review of Hulsmeyer’s complaint, however, demonstrates the inapplicability of that statute.”
Pytlinski v. Brocar Prods., Inc., 760 N.E.2d 385 (Ohio 2002). “Appellees argued that Pytlinski’s complaint was time-barred by the one-hundred-eighty-day limitations period set forth in R.C. 4113.52, the Ohio Whistleblower Act.”
Ehrlich v. Kovack, 135 F. Supp. 3d 638 (N.D. Ohio 2015). “Specifically, Defendants assert-the whistleblower statute relied on by Plaintiff, Ohio Rev.Code § 4113.52, pro *650 vides protection for private sector employees who report information about their employer.”
Piazza v. Cuyahoga Cty. (Slip Opinion), 2019 Ohio 2499 (Ohio 2019).
— Ohio Rev. Code § 4113.52(A)(1) — 24 cases
Lee v. Cardington (Slip Opinion), 2014 Ohio 5458 (Ohio 2014). “] Employment relations—R.C. 4113.52—Whistleblower protection—Reporting of employer’s criminal violations—Standards that must be met to qualify for protection.”
Herrington v. Daimlerchtysler Corp., 262 F. Supp. 2d 861 (N.D. Ohio 2003).
Contreras v. Ferro Corp., 652 N.E.2d 940 (Ohio 1995). “The first is whether the court of appeals erred in finding that appellees were entitled to summary judgment on Contreras’s claim for violations of R.C. 4113.52, Ohio’s Whistleblower Statute.”
Kulch v. Structural Fibers, Inc., 677 N.E.2d 308 (Ohio 1997). “The first is whether the court of appeals erred in finding that appellees were entitled to summary judgment on Kulch’s statutory cause of action for violations of R.C. 4113.52, Ohio’s Whistleblower Statute.”
Pytlinski v. Brocar Prods., Inc., 760 N.E.2d 385 (Ohio 2002). “Appellees argued that Pytlinski’s complaint was time-barred by the one-hundred-eighty-day limitations period set forth in R.C. 4113.52, the Ohio Whistleblower Act.”
— Ohio Rev. Code § 4113.52(A)(1)(A) — 1 case
Kaiman v. Teledyne Instruments, Inc. (S.D. Ohio 2022).
— Ohio Rev. Code § 4113.52(A)(1)(a) — 42 cases
Kulch v. Structural Fibers, Inc., 677 N.E.2d 308 (Ohio 1997). “The first is whether the court of appeals erred in finding that appellees were entitled to summary judgment on Kulch’s statutory cause of action for violations of R.C. 4113.52, Ohio’s Whistleblower Statute.”
Kulch v. Structural Fibers, Inc., 1997 Ohio 219 (Ohio 1997). “] Employment relations—At-will employee discharged or disciplined for filing complaint with OSHA is entitled to maintain common-law tort action against employer for wrongful discharge/discipline in violation of public policy—R.C. 4113.52, construed. __________________ 1.”
Contreras v. Ferro Corp., 652 N.E.2d 940 (Ohio 1995). “The first is whether the court of appeals erred in finding that appellees were entitled to summary judgment on Contreras’s claim for violations of R.C. 4113.52, Ohio’s Whistleblower Statute.”
Dobrski v. Ford Motor Co., 698 F. Supp. 2d 966 (N.D. Ohio 2010). “) Although it is unclear in the Complaint what legal theory Dobrski relies upon to support this claim, his briefing clarifies that he is asserting a claim for wrongful discharge in violation of public policy under Ohio law.”
Poluse v. City of Youngstown, 735 N.E.2d 505 (Ohio Ct. App. 1999). “Appellant initiated this action below under R.C. 4113.52, Ohio’s Whistleblower Statute.”
— Ohio Rev. Code § 4113.52(A)(1)(b) — 7 cases
Kulch v. Structural Fibers, Inc., 677 N.E.2d 308 (Ohio 1997). “The first is whether the court of appeals erred in finding that appellees were entitled to summary judgment on Kulch’s statutory cause of action for violations of R.C. 4113.52, Ohio’s Whistleblower Statute.”
Contreras v. Ferro Corp., 652 N.E.2d 940 (Ohio 1995). “The first is whether the court of appeals erred in finding that appellees were entitled to summary judgment on Contreras’s claim for violations of R.C. 4113.52, Ohio’s Whistleblower Statute.”
Ehrlich v. Kovack, 135 F. Supp. 3d 638 (N.D. Ohio 2015). “Specifically, Defendants assert-the whistleblower statute relied on by Plaintiff, Ohio Rev.Code § 4113.52, pro *650 vides protection for private sector employees who report information about their employer.”
Kulch v. Structural Fibers, Inc., 1997 Ohio 219 (Ohio 1997). “] Employment relations—At-will employee discharged or disciplined for filing complaint with OSHA is entitled to maintain common-law tort action against employer for wrongful discharge/discipline in violation of public policy—R.C. 4113.52, construed. __________________ 1.”
Poluse v. City of Youngstown, 735 N.E.2d 505 (Ohio Ct. App. 1999). “Appellant initiated this action below under R.C. 4113.52, Ohio’s Whistleblower Statute.”
— Ohio Rev. Code § 4113.52(A)(2) — 10 cases
Kulch v. Structural Fibers, Inc., 677 N.E.2d 308 (Ohio 1997). “The first is whether the court of appeals erred in finding that appellees were entitled to summary judgment on Kulch’s statutory cause of action for violations of R.C. 4113.52, Ohio’s Whistleblower Statute.”
Kulch v. Structural Fibers, Inc., 1997 Ohio 219 (Ohio 1997). “] Employment relations—At-will employee discharged or disciplined for filing complaint with OSHA is entitled to maintain common-law tort action against employer for wrongful discharge/discipline in violation of public policy—R.C. 4113.52, construed. __________________ 1.”
Poluse v. City of Youngstown, 735 N.E.2d 505 (Ohio Ct. App. 1999). “Appellant initiated this action below under R.C. 4113.52, Ohio’s Whistleblower Statute.”
Lee v. Cardington (Slip Opinion), 2014 Ohio 5458 (Ohio 2014). “] Employment relations—R.C. 4113.52—Whistleblower protection—Reporting of employer’s criminal violations—Standards that must be met to qualify for protection.”
Pytlinski v. Brocar Prods., Inc., 760 N.E.2d 385 (Ohio 2002). “Appellees argued that Pytlinski’s complaint was time-barred by the one-hundred-eighty-day limitations period set forth in R.C. 4113.52, the Ohio Whistleblower Act.”
— Ohio Rev. Code § 4113.52(A)(3) — 12 cases
Contreras v. Ferro Corp., 652 N.E.2d 940 (Ohio 1995). “The first is whether the court of appeals erred in finding that appellees were entitled to summary judgment on Contreras’s claim for violations of R.C. 4113.52, Ohio’s Whistleblower Statute.”
Dobrski v. Ford Motor Co., 698 F. Supp. 2d 966 (N.D. Ohio 2010). “) Although it is unclear in the Complaint what legal theory Dobrski relies upon to support this claim, his briefing clarifies that he is asserting a claim for wrongful discharge in violation of public policy under Ohio law.”
Fox v. City of Bowling Green, 668 N.E.2d 898 (Ohio 1996).
Hill v. Mr. Money Fin. Co., 491 F. Supp. 2d 725 (N.D. Ohio 2007).
Thatcher v. Goodwill Indus. of Akron, 690 N.E.2d 1320 (Ohio Ct. App. 1997).
— Ohio Rev. Code § 4113.52(A)(l)(a) — 1 case
State ex rel. Stoicoiu v. Stow-Munroe Falls City Sch. Dist. Bd. of Edn., 2024 Ohio 5799 (Ohio Ct. App. 2024).
— Ohio Rev. Code § 4113.52(A)(l)(b)(3) — 1 case
Black v. Columbus Pub. Schs., 124 F. Supp. 2d 550 (S.D. Ohio 2000).
— Ohio Rev. Code § 4113.52(B) — 29 cases
Fox v. City of Bowling Green, 668 N.E.2d 898 (Ohio 1996).
Hill v. Mr. Money Fin. Co., 491 F. Supp. 2d 725 (N.D. Ohio 2007).
Thatcher v. Goodwill Indus. of Akron, 690 N.E.2d 1320 (Ohio Ct. App. 1997).
Pytlinski v. Brocar Prods., Inc., 760 N.E.2d 385 (Ohio 2002). “Appellees argued that Pytlinski’s complaint was time-barred by the one-hundred-eighty-day limitations period set forth in R.C. 4113.52, the Ohio Whistleblower Act.”
Gutierrez v. Sundancer Indian Jewelry, Inc., 868 P.2d 1266 (N.M. Ct. App. 1993).
— Ohio Rev. Code § 4113.52(B)(1) — 1 case
Herrington v. Daimlerchtysler Corp., 262 F. Supp. 2d 861 (N.D. Ohio 2003).
— Ohio Rev. Code § 4113.52(C) — 5 cases
Pytlinski v. Brocar Prods., Inc., 760 N.E.2d 385 (Ohio 2002). “Appellees argued that Pytlinski’s complaint was time-barred by the one-hundred-eighty-day limitations period set forth in R.C. 4113.52, the Ohio Whistleblower Act.”
Contreras v. Ferro Corp., 652 N.E.2d 940 (Ohio 1995). “The first is whether the court of appeals erred in finding that appellees were entitled to summary judgment on Contreras’s claim for violations of R.C. 4113.52, Ohio’s Whistleblower Statute.”
Pytlinski v. Brocar Prod., Inc., 2002 Ohio 66 (Ohio 2002). “Appellees argued that Pytlinski’s complaint was time-barred by the one-hundred-eighty-day limitations period set forth in R.C. 4113.52, the Ohio Whistleblower Act.”
Lee v. Cardington (Slip Opinion), 2014 Ohio 5458 (Ohio 2014). “] Employment relations—R.C. 4113.52—Whistleblower protection—Reporting of employer’s criminal violations—Standards that must be met to qualify for protection.”
Kelly v. Lambda Rsch., Inc., 89 F. App'x 535 (6th Cir. 2004).
— Ohio Rev. Code § 4113.52(D) — 31 cases
Pytlinski v. Brocar Prods., Inc., 760 N.E.2d 385 (Ohio 2002). “Appellees argued that Pytlinski’s complaint was time-barred by the one-hundred-eighty-day limitations period set forth in R.C. 4113.52, the Ohio Whistleblower Act.”
Pytlinski v. Brocar Prod., Inc., 2002 Ohio 66 (Ohio 2002). “Appellees argued that Pytlinski’s complaint was time-barred by the one-hundred-eighty-day limitations period set forth in R.C. 4113.52, the Ohio Whistleblower Act.”
Kulch v. Structural Fibers, Inc., 677 N.E.2d 308 (Ohio 1997). “The first is whether the court of appeals erred in finding that appellees were entitled to summary judgment on Kulch’s statutory cause of action for violations of R.C. 4113.52, Ohio’s Whistleblower Statute.”
Celeste v. Wiseco Piston, 784 N.E.2d 1198 (Ohio Ct. App. 2003). “52 and appellant’s failure to allege that he complied with the written notice requirements of the statute.”
Hulsmeyer v. Hospice of Sw. Ohio, Inc. (Slip Opinion), 2014 Ohio 5511 (Ohio 2014). “24, Hulsmeyer could have reported any reasonable suspicion of abuse or neglect to her employer pursuant to Ohio’s Whistleblower Statute, R.C. 4113.52. Review of Hulsmeyer’s complaint, however, demonstrates the inapplicability of that statute.”
— Ohio Rev. Code § 4113.52(E) — 11 cases
Kulch v. Structural Fibers, Inc., 677 N.E.2d 308 (Ohio 1997). “The first is whether the court of appeals erred in finding that appellees were entitled to summary judgment on Kulch’s statutory cause of action for violations of R.C. 4113.52, Ohio’s Whistleblower Statute.”
Kulch v. Structural Fibers, Inc., 1997 Ohio 219 (Ohio 1997). “] Employment relations—At-will employee discharged or disciplined for filing complaint with OSHA is entitled to maintain common-law tort action against employer for wrongful discharge/discipline in violation of public policy—R.C. 4113.52, construed. __________________ 1.”
Pytlinski v. Brocar Prods., Inc., 760 N.E.2d 385 (Ohio 2002). “Appellees argued that Pytlinski’s complaint was time-barred by the one-hundred-eighty-day limitations period set forth in R.C. 4113.52, the Ohio Whistleblower Act.”
Rheinecker v. Forest Labs., Inc., 813 F. Supp. 1307 (S.D. Ohio 1993).
Pytlinski v. Brocar Prod., Inc., 2002 Ohio 66 (Ohio 2002). “Appellees argued that Pytlinski’s complaint was time-barred by the one-hundred-eighty-day limitations period set forth in R.C. 4113.52, the Ohio Whistleblower Act.”
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