The Fifth Circuit affirmed the U.S. Department of Labor Administrative Review Board’s decision that Halliburton’s disclosure of a whistleblower’s identity to colleagues constituted an “adverse action,” i.e., an action harmful enough that it might dissuade others from engaging in statutorily protected whistleblowing, for which whistleblower’s protected conduct was a contributing factor. Halliburton, Inc. v. Admin. Review Bd., 771 F.3d 254 (5th Cir. 2014) (No. 13-60323). As a result, this disclosure amounted to illegal retaliation under the Sarbanes-Oxley Act. After the whistleblower internally reported what he believed were questionable accounting practices, the whistleblower lodged with the SEC a complaint against Halliburton. After his boss identified him as the SEC whistleblower, his colleagues began treating him differently, including refusing to work with him. The court emphasized that Halliburton’s identification of the whistleblower was a “targeted creation of an environment in which the whistleblower is ostracized” and a “potential deprivation of opportunities for future advancement.” Thus, the court affirmed an award to the whistleblower for noneconomic compensatory damages—namely, for emotional distress and reputational harm.