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Oregon Revised Statutes

Or. Rev. Stat. § 659A.230 (2026)

Discrimination for initiating or aiding in criminal or civil proceedings prohibited; remedies not exclusive

✓ current as of May 2026
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      659A.230 Discrimination for initiating or aiding in criminal or civil proceedings prohibited; remedies not exclusive. (1) It is an unlawful employment practice for an employer to discharge, demote, suspend or in any manner discriminate or retaliate against an employee with regard to promotion, compensation or other terms, conditions or privileges of employment for the reason that the employee has in good faith reported criminal activity by any person, has in good faith caused a complainant’s information or complaint to be filed against any person, has in good faith cooperated with any law enforcement agency conducting a criminal investigation, has in good faith brought a civil proceeding against an employer or has testified in good faith at a civil proceeding or criminal trial.

      (2) For the purposes of this section, “complainant’s information” and “complaint” have the meanings given those terms in ORS 131.005.

      (3) The remedies provided by this chapter are in addition to any common law remedy or other remedy that may be available to an employee for the conduct constituting a violation of this section. [Formerly 659.550]

Notes of Decisions
Cited in 52 cases (20 in the last 5 years), 2002–2026 · leading case: Janell Howard v. City of Coos Bay, 871 F.3d 1032 (9th Cir. 2017).
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Janell Howard v. City of Coos Bay, 871 F.3d 1032 (9th Cir. 2017). · cites it 8× “§ 1983 , alleging that the City violated the First Amendment of the United States Constitution, and Or. Rev. Stat. § 659A.230, Oregon’s whistleblower-protection law.”
Folz v. State ex rel. Oregon Dep't of Transp., 404 P.3d 1036 (Or. Ct. App. 2017). · cites it 15× “203, 1 and ORS 659A.230. 2 Plaintiff claimed that defendants engaged in a series of retaliatory employment actions against her for reporting possible violations of disability discrimination laws in the course of her employment with the Oregon Department of Transportation (ODOT).”
Huitt v. Optum Health Servs., 216 F. Supp. 3d 1179 (D. Or. 2016). · cites it 10× “and were therefore not protected by ORS 659A.230.”); Mantia v. Hanson, 190 Or.”
Allison v. Dolich, 518 P.3d 591 (Or. Ct. App. 2022). · cites it 17× “A civil proceeding, as used in ORS 659A.230 and these rules, includes a proceeding before an administrative agency or a court.”
Hall v. State, 366 P.3d 345 (Or. Ct. App. 2015). · cites it 11× “203, 4 and ORS 659A.230, 5 common-law wrongful discharge, and a claim for violation of due process rights under 42 USC section 1983 .”
Livingston v. Metro. Pediatrics, LLC, 227 P.3d 796 (Or. Ct. App. 2010). · cites it 5× “Plaintiff brought common-law claims against defendants for wrongful discharge, breach of contract, intentional infliction of emotional distress, and intentional interference with economic relations, and brought statutory claims of employment discrimination, ORS 659A.230…”
McManus v. Auchincloss, 353 P.3d 17 (Or. Ct. App. 2015). · cites it 10× “Plaintiff identifies the private-employeewhistleblower statute, ORS 659A.230, 5 as the legislative expression of that public policy, and the legislative history of that statute as evidence that that public duty is incumbent upon all private employees, including domestic service…”
Huber v. Oregon Dep't of Educ., 230 P.3d 937 (Or. Ct. App. 2010). · cites it 6× “On appeal, plaintiff contends that the trial court erred in granting defendants’ summary judgment motion concerning (1) his claim pursuant to 42 USC section 1983 for violation of plaintiffs First Amendment rights; (2) his claim for retaliation pursuant to ORS 659A.230 for…”
Roberts v. Oregon Mut. Ins., 255 P.3d 628 (Or. Ct. App. 2011). · cites it 17× “In her complaint, she alleges claims for common-law wrongful discharge and unlawful employment discrimination under ORS 659A.230. In her claim for wrongful discharge, she alleges, in part: “4.”
Matteo Brunozzi v. Cable Commc'ns, Inc., 851 F.3d 990 (9th Cir. 2017). “(discussing that ORS 659A.230(1) provides context of criminal activity, complaint, investigation, and trial and civil proceeding).”
Larmanger v. Kaiser Found. Health Plan, 895 F. Supp. 2d 1033 (D. Or. 2012). · cites it 4× “199, (5) violation of whistleblower protection under Oregon Revised Statute § 659A.230, (6) retaliation for opposing unlawful discrimination in violation of Oregon Revised Statute § 659A.”
Olsen v. Deschutes Cnty., 127 P.3d 655 (Or. Ct. App. 2006). · cites it 2× “Now, an aggrieved plaintiff can seek compensatory damages under ORS 659A.230(3); that statute, in turn, allows plaintiffs to seek common-law remedies.”
Show all 52 citing cases →
— Or. Rev. Stat. § 659A.230(1) — 18 cases
Allison v. Dolich, 518 P.3d 591 (Or. Ct. App. 2022). “A civil proceeding, as used in ORS 659A.230 and these rules, includes a proceeding before an administrative agency or a court.”
Janell Howard v. City of Coos Bay, 871 F.3d 1032 (9th Cir. 2017). “§ 1983 , alleging that the City violated the First Amendment of the United States Constitution, and Or. Rev. Stat. § 659A.230, Oregon’s whistleblower-protection law.”
Matteo Brunozzi v. Cable Commc'ns, Inc., 851 F.3d 990 (9th Cir. 2017). “(discussing that ORS 659A.230(1) provides context of criminal activity, complaint, investigation, and trial and civil proceeding).”
Roberts v. Oregon Mut. Ins., 255 P.3d 628 (Or. Ct. App. 2011). “In her complaint, she alleges claims for common-law wrongful discharge and unlawful employment discrimination under ORS 659A.230. In her claim for wrongful discharge, she alleges, in part: “4.”
Folz v. State ex rel. Oregon Dep't of Transp., 404 P.3d 1036 (Or. Ct. App. 2017). “203, 1 and ORS 659A.230. 2 Plaintiff claimed that defendants engaged in a series of retaliatory employment actions against her for reporting possible violations of disability discrimination laws in the course of her employment with the Oregon Department of Transportation (ODOT).”
— Or. Rev. Stat. § 659A.230(3) — 1 case
Olsen v. Deschutes Cnty., 127 P.3d 655 (Or. Ct. App. 2006). “Now, an aggrieved plaintiff can seek compensatory damages under ORS 659A.230(3); that statute, in turn, allows plaintiffs to seek common-law remedies.”
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