312 U.S. 52, 67, 61 S.Ct. 399, 85 L.Ed. 581 (1941). The False Claims Act created a comprehensive scheme designed to protect federal whistleblowers while discouraging frivolous suits by limiting available remedies. See 31 U.S.C. § 3730(h). California’s wrongful discharge tort is inconsistent with this latter objective because it allows recovery of punitive damages. Several of the federal statutes the False Claims Act was modeled after have been found to preempt, state tort remedies for wrongful discharge. See S.Rep. No. 345, 9th Cong., 2nd. Sess. 73 (1986), reprinted in 1986 U.S.C.C.A.N. 5266, 5299 (stating Section 3730(h) was modeled in part after the whistleblower protections, found in 42 U.S.C. § 5851), and Snow v. Bechtel Const. Inc., 647 F.Supp. 1514, 1518-19 (C.D.Cal.1986) (<HOLDING>). See also S.Rep. No. 345, reprinted in 1986
holding that liability for the tort of wrongful discharge based on refusal to commit an unlawful act can extend to the corporate officers who authorized or directed the discharge recognizing tort of wrongful discharge in violation of public policy recognizing tort of wrongful discharge holding the whistleblower protection provision of the energy reorganization act 42 usc  5851 preempted californias wrongful discharge tort recognizing cause of action for wrongful discharge