Halliburton, Inc. v. Administrative Review Board

Anthony Menendez, an employee of Halliburton, used the company’s internal procedures to submit a complaint to management about what he thought were “questionable” accounting practices. Menendez also lodged a complaint about the company’s accounting practices with the Securities and Exchange Commission (“SEC”), which led the SEC to contact Halliburton and instruct it to retain certain documents during the pendency of the SEC’s investigation. When Halliburton received the SEC’s notice of the investigation, the company inferred from Menendez’s internal reports that Menen-dez must have reported…