loyers, but do not publicly disclose such instructions (Westman 20). (2) The active whistle-blower - describes employees that voice their concerns over illegal activity conducted by their employer, and take steps either internally or externally to expose such activity. The active whistle-blower usually creates the most controversy because this person is under the employ of the people or organization who are the object of the complaint (Westman 21). (3) The embryonic whistle-blower - describes employees who have been terminated before they have the opportunity to expose their employers' practices. These employees are usually terminated because the employer suspects that they represent a potentially sensitive or unfavorable predicament (Westman 22). The various forms of retribution that whistle-blowers endure at the hands of employers both financially and psychologically for attempting to correct mismanagement, fraud, and dishonesty are often too much for the whistle-blower to bear. Careers are in jeopardy because individuals with strong ethics decide to pursue law suits against their employers. One example is where the US Forest Service employees found their careers ruined by either demotions or loss of jobs when caught speaking out in favor of the environment or sound science, or when simply obeying the law (Smith 24). In order to circumvent some of these abuses, congress has set up special agencies and law in an attempt to defend whistle-blowers and to protect the public against government corruption. Although, whistle-blowing has become a more recent problem, it is by no means something entirely new. The False Claim Act of 1863 was the beginning of the legislative journey down the long road to modem day legislation. Congress enacted the False Claims Act to address the problem of profiteers who were taking advantage of shortages caused by the Civil War to charge outlandish prices to the Federal Gover...