It's been almost three years since the Michigan Court of Appeals decided Wielen v City of Bay Cityin an unpublished decision. No. 298256, 2012 WL 407266 (Mich Ct App February 9, 2012). In spite of its increasing shelf life, it has kept a low profile and hasn't been discussed in any Michigan appellate opinions since 2012.

The case is interesting because it indicates that liability under the Act can arise if a supervisor appears to be supporting or appeasing retaliating coworkers. Wielen dealt with a retaliation/wrongful termination claim under the WPA, in which a refuse collection worker was terminated after making various safety complaints and getting into workplace disputes with coworkers. While the Court of Appeals ultimately affirmed summary disposition based on the worker's failure to disprove pretext (the employer allegedly fired him for physically hitting a coworker in anger, as opposed to self-defense), the Court did confirm that the worker met the "causation" element of his claim. Causation was established in part by the supervisor's response to workplace tension: the supervisor's response "could cause a trier of fact to infer that [the employer] perceived [the worker] as a liability who should be quieted or eliminated for the sake of workplace cohesion."

In spite of being unpublished, Wielen stands as an example of what can satisfy the causation element of the WPA. It's certainly worth a read -- I think the opinion is just over three pages.