In Nollner v. Southern Baptist Convention, Inc., Nos. 3:12-cv-00040, 3:12-cv-00043, 2012 WL 1108923 (M.D. Tenn. Ap. 3, 2012), the court held that the plaintiffs failed to state a claim under the Dodd-Frank Wall Street Reform and Consumer Protection Act (“DFA”) against the Southern Baptist Convention. The International Mission Board of the Convention allegedly recruited the plaintiff to perform missionary-related work, including construction management, for a new office building in New Delhi, India. The assignment was allegedly for at least 24 months and included a “Spouse Assignment Description.” The plaintiffs sold all their assets and gave up their jobs in anticipation of the move. They alleged that the defendants hired a contractor and architect before they arrived without a competitive bidding process; that the workmanship and materials utilized were below standard; that the contractor and architect tried to bribe Mr. Nollner and were paying bribes to local officials; and that the defendants had received an illegal permit. They also alleged that Mr. Nollner reported these activities, and that after he refused to resign was terminated. The court held that the Foreign Corrupt Practices Act (“FCPA”) does not create a private right of action under the circumstances and that only the Department of Justice has jurisdiction over the defendants under the FCPA. Likewise, the court declined to interpret the DFA as extending its whistleblower protections to companies that otherwise have no relationship to the Securities Exchange Commission and that have not committed securities violations. Consequently, the court ruled that the plaintiffs could not state a DFA claim. The federal court declined to exercise supplemental jurisdiction over the state causes of action and remanded the state claims for breach of contract, promissory estoppel and retaliatory discharge to state court.