Rebekah Jones v. Florida Department of Health, Joseph A. Ladapo, in his official capacity, and Shamarial Roberson, individually

The First District affirmed final summary judgments rejecting a high-profile public-sector whistleblower and First Amendment retaliation suit. The court held that Florida's public sector Whistle-blower's Act contains no cause of action for 'preemptive retaliation' — a plaintiff terminated before making a statutorily compliant written disclosure has no claim — because the Act is a limited waiver of sovereign immunity that must be strictly construed. It further held that a government employee's public statements about the very program she was assigned to manage are made as an employee rather than as a citizen and are therefore unprotected under Garcetti.

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