The Tenth Circuit applied Chevron deference to Administrative Review Board (“ARB”) interpretations of § 1514 of the Sarbanes-Oxley Act (“SOX”) in affirming a decision that Lockheed Martin Corporation violated SOX by constructively discharging an employee after she made a protected ethics report against her superior. Lockheed Martin Corp. v. Admin. Review Bd., 717 F.3d 1121 (10th Cir. 2013) (No. 11-9524). The superior allegedly misused Lockheed funds while engaging in sexual relationships with U.S. soldiers she met through a Lockheed pen pal program. After the employee reported the alleged misconduct to management, Lockheed demoted her, put her on layoff notice, and assigned her to an office that doubled as a storage room. An administrative law judge found that the employee had engaged in activity protected by § 1514 when she reported what she reasonably believed to be mail or wire fraud by her superior, and this activity was a contributing factor in the employee’s constructive discharge. The ARB agreed. The Tenth Circuit affirmed and rejected Lockheed’s argument that SOX protects only activity relating to shareholder fraud. The court also held that even if the language in SOX was ambiguous regarding the protected activity, the ARB’s broad interpretation of protected activity under SOX was entitled to deference. The Supreme Court will have an opportunity to address whether Chevron deference should be applied to ARB interpretations of SOX whistleblower protections in Lawson v. FMR LLC, in which the Court has granted certiorari to review a First Circuit decision that rejected an ARB interpretation.