finding the “close temporal proximity” between a special meeting at which- former employees in county’s purchasing department complained to the commissioner of perceived irregularities in the county’s bidding process and adverse employment" actions taken against the same employees by their supervisor was sufficient to permit reasonable jury to conclude that incidents were causally connected
How later courts described this case
- finding the “close temporal proximity” between a special meeting at which- former employees in county’s purchasing department complained to the commissioner of perceived irregularities in the county’s bidding process and adverse employment" actions taken against the same employees by their supervisor was sufficient to permit reasonable jury to conclude that incidents were causally connected
- holding in First Amendment retaliation case that unwarranted reprimands, a negative work evaluation, threat of job loss through dissolution of the plaintiffs’ division, threat of suspension without pay, removal of job duties, and exclusion from meetings did not constitute adverse employment action, either singly or when considered in the aggregate
- concluding that Plaintiffs did not establish that they suffered an adverse employment action because they did not allege “that the reprimands or the threats of suspension and job loss affected the terms and conditions of their employment or their status as employees.”
- holding that “reprimands[,]” “negative evaluations[,]” “threat of job loss[,]” and “threats of suspensions without pay” were not an adverse employment action—even considered in the aggregate
Written by the judges who cited it.
The opinion
BLACK, Circuit Judge,
concurring:
I concur in the result reached by the majority. I would like to emphasize that there is a disputed question of fact as to whether the “main thrust” of the August 27, 1998 meeting was to discuss bidding irregularities, as Plaintiffs allege, or general work environment concerns, as Commissioner Darnell claims. This issue is best resolved by a jury, and not on a motion for summary judgment.