While some states had whistleblower statutes during the early part of the twentieth century, most of the action in regards to state legislation to protect whistleblowers occurred in the latter half of the century. In the 1980s, for example, 15 states passed general whistleblower statutes, and many state courts further developed a public policy exception to the at-will employment doctrine for whistleblowers. The result is that state courts have become a major arena for whistleblower cases.