Rowan v. Tractor Supply Co.

Pursuant to the provisions of Rule 5:42, the United States District Court for the Western District of Virginia entered a certification order requesting that we exercise our certification jurisdiction and answer the following question:

Does a complaint state a Bowman claim under § 18.2-460 when the plaintiff, an at-will employee, alleges that her employer terminated her employment because she refused to yield to employer’s demand that she discontinue pursuing criminal charges of assault and battery against a fellow employee?

The district court concluded that the issue presented by this question…