In Shoemaker v. Myers (1990) 52 Cal. 3d 1, the Supreme Court addressed the scope of workers' compensation exclusivity. In Shoemaker v. Myers, a state employee was harassed by his supervisors and ultimately fired in connection with his complaints about complicity of his supervisors in illegal activities by state contractors. ( Shoemaker v. Myers, supra, 52 Cal. 3d at pp. 7-8.) The court concluded that, because of the strong and explicit statutory prohibition on retaliation against governmental "whistleblowers," the supervisors' conduct fell outside the "compensation bargain" as defined in Cole. Because the supervisors' intentional conduct fell outside the compensation bargain, the employee was entitled to seek compensation for his emotional distress injury in a civil action. (52 Cal. 3d at p. 23.)