On December 31st, the Fourth Circuit, in an issue of first impression, held that the Sarbanes-Oxley Act's whistleblower provisions establish a complainant's right to de novo review in federal district court if the Labor Department does not issue a "final decision" within the statutory 180-day period. "[E]ven if the 180-day statutory period is arguably both overly aggressive and not the most efficient use of administrative and judicial resources, [complainant] was entitled to de novo review in the court below." Stone v. Instrumentation Laboratory Company.