The Fourth Circuit has joined a majority of other circuits in holding that the anti-retaliation provision of the Fair Labor Standards Act, 29 U.S.C. § 215(a)(3), applies to retaliation based on internal complaints. Section 215(a)(3) makes it unlawful “to discharge or in any other manner discriminate against any employee because such employee has filed any complaint or instituted or caused to be instituted any proceeding under or related to this chapter, or has testified or is about to testify in any such proceeding, or has served or is about to serve on an industry committee.” In Minor v. Bostwick Laboratories, Inc., 669 F.3d 428 (4th Cir. 2012) (No 10-1258), the plaintiff alleged that she was terminated because she had told her employee’s chief operating officer that her supervisor routinely altered employees’ time sheets to falsely reflect that they had not worked overtime. The district court dismissed her complaint on the basis that the statute, by virtue of its plain language, applied only in circumstances in which an official, formal proceeding resulted from the employee’s complaint. The Fourth Circuit noted that the U.S. Supreme Court had expressly left this issue open in Kasten v. Saint-Gobain Performance Plastics Corp., 131 S. Ct. 1325 (2011), which found that a “filed” complaint need not be in writing. The court then found the phrase “filed any complaint” to be ambiguous and interpreted it broadly in order to accord with the broad remedial purpose of the statute, noting as well that its broad interpretation was consistent with the interpretation followed by the Secretary of Labor and the EEOC.