Seventh Circuit puts finer point on adverse employment actions

Description

Abstract: When a police officer charged his employer with race discrimination and retaliation, his claims were dismissed on technical grounds. When he offered the appeals court an amended complaint that omitted a previous charge that he’d been denied a shift-change request because of race, the defendants argued that he’d failed to allege specific facts indicating an adverse employment action. This article explains why the court disagreed, finding that his allegations were sufficient to plead that a denial of transfer was a materially adverse employment action in this instance. Lavalais v. Village of Melrose Park, No. 13-1200, Oct. 24, 2013 (7th Cir.) Cheek v. W. & S. Life Ins. Co., No. 93-1840, Aug. 1, 1994 (7th Cir.) Oest v. Ill. Dep’t of Corrs., 240 F.3d 605, 612–13, 2001 (7th Cir.)