motion several times because he had a history of being a whistle-blower. On numerous occasions, he had written letters reporting wrong doing, waste, and inefficiency within the department. Although the court recognized that the police department has discretion in promotion matters, it decided that the officer in question had the right to prove that the exercise of his First Amendment rights was the major factor in the police department's decision not to promote him (singer 19). Another agency was enacted in 1978, when congress set up a Federal organization called the Office of the Special Counsel (OSC) for the purpose of defending the First Amendment rights of federal whistle-blowers, and to offer the public a safeguard against government corruption (Vinten 42). Today, whistle-blowers have some resources at their disposal to assist them in their pursuit. Despite support by the Justice Department under the False Claims Act and various other groups on the side of the whistle-blower, the psychological impact upon their lives can be overwhelming. The perils that whistle-blowers face can be very draining both financially as well as psychologically. Some companies go to any length in their pursuit of trying to discredit the whistle-blowers, which includes the hiring of private agencies which often times implement illegal methods to discredit the whistle-blowers, creating an extremely stressful environment for the whistle-blower (Smith 26). Another illegal tactics that employers used is "fitness for duty" where the employer orders psychiatric exams on the whistle-blower to discredit their testimony and make them appear crazy. The employer would build a file against the whistle-blower and then send him for evaluation whereupon he would be determined unfit for duty, whereby the charges brought by the whistle-blower would die upon his discharge on disability (Soeken 42). The duty of loyalty to the employer's interest is also ...