Tuesday, February 5, 2019

Whistleblowing and the Justifications


Whistleblowing and the Justifications

One of the awkward truths of whistleblowing is that both sides think they are doing the right thing.  We whistleblowers believe that we are disclosing a misdeed by our employer.  Our employers are jerks that think they did nothing wrong and firing us was a great idea.

In “Ruthlessness in Public Life” Thomas Nagel observes that the great modern crimes are committed by officials in political, military, and business organizations[1].  As group members, they can do far greater harm than as private individuals.  They can oppress, murder, and steal far more than imaginable by most individuals.

Nagel wrote not long after the U.S. arguably committed war crimes in southeast Asia, resulting in the deaths of more than one million people.  And not long after fraud by Enron executives destroyed $11 billion in shareholder value.  Most of us small time whistleblowers are not involved in such grand misdoings, although stakes can still get pretty big.

A couple of whistleblowers found problems at venerable Walgreens.  S. Christopher Schulte, a Walgreens pharmacist, and Adam Rahimi, a pharmacist formerly employed by Walgreens, brought a false claims lawsuit against the company.  They charged Walgreens intentionally overfilled prescriptions for insulin injection pens.  If a customer required 7 pens, Walgreens would dispense 2 boxes of 5 and then remind the customer to refill the prescription after 7 were used.  The result was that Medicare was overbilled millions of dollars.  Walgreens admitted its misbehavior and agreed to pay $209 million to settle the claims.

Recently Walgreens settled a false claims suit brought by Marc Baker.  Baker saw Walgreens encourage its Medicare customers to sign-up for its Prescriptions Savings Club so they’d renew prescriptions at its pharmacies.  But instead of charging Medicare discounted prices, it used its regular list prices.  Walgreens again admitted its wrongdoing and agreed to pay a settlement, this time $60 million.

Even a man as prominent as Stefano Pessina, Walgreens’ CEO, might have trouble stealing $269 million from taxpayers on his own.  But with the help of the world’s largest pharmacy company, the task was easier.

On a much smaller scale, Jenny Niklaus, CEO of HomeFirst Services during part of my time there, could not have stolen large sums as an individual.  As CEO, though, she employed HomeFirst to grab $130,000 from Santa Clara County and $138,000 from the City of San Jose.  Unlike Walgreens, though, HomeFirst never returned the money or admitted guilt.

For Nagel, these seemingly frequent bursts of immoral action derive not just from the capacity of officials to do more wrong than private citizens.  It comes as a by-product of their duties.

The actions of an official or an organization can appear brutal but still be proper, Nagel says.  Take taxation, for example.  It can be seen as little different from highway robbery: the theft of wages or wealth.  But the morality of the taxing agency – judged by the equity of its actions and its use of money for the common good – can justify the taxation.  When those principles are violated – if taxes are unfairly drawn or the money is wasted – then the ruthlessness can lose its right.

An organizational leader – in the U.S. military, Walgreens, or even HomeFirst – must submit to constraints on her behavior.  She should put the organization’s interests above outsiders’.  She must not use her position to enrich herself unduly.  She is bound to treat members of the organization equitably. 

Nagel writes that an official can sometimes forget the limits on her actions.  She might decide that all those restrictions on her behavior give her the moral cushion to commit unethical acts.  She might decide that she has no obligation to consider anything other than the interest of her group.  Or she might be confronted by such a complex array of interests and responsibilities that she fails to weigh the consequences of her actions appropriately,

Nagel’s list of ethical lapses seems plausible.  Niklaus objected to my concern about HomeFirst’s possible violation of licensing regulations.  She argued that the good done in the company’s homeless shelter should not be lost to petty rules.  She and HomeFirst’s Board discussed how to deal with me for telling authorities about possible legal violations.  Their attorney advised firing me right away because of damage I might do with my complaints.  Niklaus saw the danger but chose to defer action just a little.  She recommended to the Board that HomeFirst should not be constrained by laws protecting whistleblowers.

Nagel’s list has been confirmed and expanded by psychologists, including Dan Ariely, Max Bazerman, Joshua Greene, Jonathan Haidt, and Ann Tenbrunsel.  But outside of research studies, it can be difficult to get into the minds of organizational leaders.  Although I thought I had proof of HomeFirst’s illegal intent, the Department of Justice and the State of California were not interested.

Unlike Walgreens, most companies and officials deny wrongdoing even after they are caught.  Sunoco recently agreed to pay $5 million to settle a lawsuit over 5,000 barrels of crude oil that spilled from its pipelines and to spend money to avoid future spills.  Still, it refused to admit having done anything wrong.  Paying the $5 million was just expedient.

Officials regularly come up with justifications that fit into Nagel’s list of moral failures.  In 1995 José Arias was hired by Angelo Dairy in Acampo, California.  A couple of years later he told Luis Angelo he was leaving for a job at another farm.  Angelo got upset and threatened to tell immigration the dairy hired undocumented workers if he left.  So Arias stayed on. 

In 2006 Arias sued Angelo Dairy for failing to provide overtime pay and rest and meal breaks.  Just before the trial in 2011, the company’s lawyer Anthony Raimondo alerted ICE that Arias might not be properly documented.  Spooked, Arias settled.  Then he filed a new suit charging retaliation by Raimondo.  That case dragged on for 6 more years until a federal appeals court ruled in his favor and he settled for $1 million.

Raimondo, though, denies any wrongdoing.  He claims he took the same approach for many of his clients and it was legal until 2013.  He said, “All I ever did was tell the truth to law enforcement.  Is that illegal?”  With this, Raimondo sounds like a whistleblower.  He wanted to make sure taxpayer money wasn’t used improperly defending illegals.  He’s a moralist.  He’s the only one in the case who didn’t break the law, he claims.

There are at least two sides to every whistleblowing case.  Each takes the high moral ground.  One may eventually be declared victor.  But that is a matter of convenience, not probity.  The judgment will not settle the matter in the minds of all parties.  Indeed, there may be no entirely convincing way to determine which is right, or even more right than the other.  In the end, the competing players may remain standing angry at the edges of the field[2].


[1] Also listen to Very Bad Wizards on the topic.
[2] Cf. Tessman, Lisa.  Moral Failure: On the Impossible Demands of Morality.  Oxford: Oxford University Press.  2015.  Especially her discussion of Bernard Williams’ “moral remainder.”

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