Section 891 of the Police Act 1996: The Implications for Civilian Employees and Chief Executives of

[118] Burlington N., 548 U.S. at 63; see, e.g.,Hawkins v. Anheuser-Busch, Inc., 517 F.3d 321, 347-48 (6th Cir. 2008) (ruling that setting fire to employee's car and threatening to "kill the bitch" was actionable as retaliation); Aviles v. Cornell Forge Co., 183 F.3d 598, 604 (7th Cir. 1999) (ruling that falsely telling police that employee had a gun and had threatened to shoot supervisor, resulting in police injuring employee so severely he was unable to work for six weeks, was actionable as retaliation); Berry v. Stevinson Chevrolet, 74 F.3d 980, 984, 986 (10th Cir. 1996) (ruling that filing false criminal charges was actionable as retaliation).

contrary to section 891 of the police act 1996

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