Huffman v. Office of Personnel Management, 263 F.3d 1341 (Fed. Cir. 2001) is a decision by the United States Court of Appeals for the Federal Circuit addressing a two decade-old conflict between the United States Congress and the U.S. Court of Appeals for the Federal Circuit over the depth of whistleblower protection available to federal civilian employees covered by the Whistleblower Protection Act of 1989. The discourse revolves around the meaning of the word 'any'. Facts of the case The complainant, Kenneth Huffman alleged that he made protected disclosures to Inspector General Patrick McFarland of the Office of Personnel Management, including that McFarland improperly preselected an agency employee for the Senior Executive Service (SES). The allegation included the accusation that the complainant was removed as an Assistant Inspector General following these communications. Huffman's removal prompted his complaint under the Whistleblower Protection Act. In 1994, the United States Congress passed an amendment to the Act. The legislative history of that amendment stated, " . . . it also is not possible to further clarify the clear language in section 2302(b)(8) that protection for 'any' whistleblowing disclosure truly means 'any.' A protected disclosure may be made as part of an employee's job duties, may concern policy or individual misconduct, and may be oral or written and to any audience inside or outside the agency, without restriction to time, place, motive or content." Under Senator Levin's view, Huffman's disclosures would have been protected. Huffman took his case to the Merit Systems Protection Board, which held that it did not have jurisdiction under the Whistleblower Protection Act to intervene in Huffman's removal. The case was argued before Chief Judge Mayer and Circuit Judges Bryson and Dyk of the Federal Circuit. James M. Eisenmann of Passman & Kaplan, P.C. argued for Huffman. James C. Caine was the trial attorney for the Commercial Litigation Branch, Civil Division, U.S. Department of Justice argued for the Office of Personnel Management. The government argued that whistleblower disclosures to persons who did not have authority to correct wrongdoing were not entitled to protection under the statute. The Federal Circuit remanded the case with respect to Huffman's disclosures concerning the conduct of employees other than his immediate supervisor. The Rule as a Summarization of Existing Case Law Despite this Congressional intent in the 1994 amendment, the United States Court of Appeals for the Federal Circuit curtailed the scope of federal law