by defining some communications outside the definition of 'whistleblower'. A series of Federal Circuit cases subsequent to 1994 took a narrow view of the scope of whistleblower protection. In Horton v. Dep't of the Navy, the court ruled that communications to co-workers, the wrong-doer, or to a supervisor were not acts of whistleblowing. In Willis v. Dep't of Agriculture, the court ruled that a whistleblower's disclosures to officials in the agency chain of command or those made in the course of normal duties were not protected. Then, finally, the court issued Huffman v. Office of Personnel Management, reaffirming Horton and Willis through the rule in Huffman. Finally, in Meuwissen v. Dep't of the Interior, the court ruled that a whistleblower's communication of previously known information does not qualify as a disclosure. In 2003, Senator Carl Levin of Michigan took to the Senate floor and noted that "[a]ll of these rulings violate clear Congressional intent to afford broad protection to whistleblower disclosures." Criticism of the case Immediately following the release of Huffman, then-U.S. Special Counsel Elaine Kaplan noted that the court did actually reject the Justice Department's argument that would have left whistleblowers unprotected except when disclosures were made to persons with the actual authority to correct the alleged wrongdoing. Kaplan noted that "had the Court endorsed this argument, it would have gutted the WPA; obviously, whistleblowers cannot be required to guess at their peril whether the individual to whom they are disclosing wrongdoing possesses the legal authority to correct it." "Moreover," she noted, "the adoption of this argument would have meant that whistleblowers would not be protected when they made disclosures to the media or the public at large—precisely the opposite of what Congress intended when it enacted the WPA." In her 2001 press statement, Kaplan also observed that the court's other rulings "appear to undermine in crucial respects the policies underlying the Whistleblower Protection Act: to encourage employees to come forward when they uncover serious wrongdoing during the course of their employment." The Office of Special Counsel noted that under the court's ruling employees are not protected when they make disclosures during the course of performing their duties, "an auditor at the Department of Defense, for example, who uncovers massive fraud and waste of funds, would not be protected against retaliation when he reports the fraud as part of his job duties up the chain of command. Similarly, a