Voluntary Job Transfer Can Be Adverse Action: 6th Circ.

Law360, New York (January 16, 2014, 6:33 PM EST) -- The Sixth Circuit ruled Tuesday that a transfer can be an adverse employment action that gives rise to a bias claim, even when the employee has requested the transfer, reviving a discrimination lawsuit against the Kalamazoo County Road Commission.

In a 2-1 decision, the appeals court reversed a summary judgment win for the commission on race, national origin and age discrimination claims brought by former employee Robert Deleon, holding that the transfer of an employee can constitute an adverse employment action, even if it does not...
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