Does the disclosure of adverse employment references constitute an adverse employment action?
MultiRegion, United States of America
The following excerpt is from Nehara v. California, Case No.: 1:10-cv-00491 - JLT (E.D. Cal. 2013):
118 F.3d at 674 (finding "dissemination of adverse employment references" constitutes an adverse employment action); Yartzoff v. Thomas, 809 F.2d 1371, 1376 (9th Cir. 1987) ("[t]ransfers of job duties and undeserved performance ratings . . . constitute adverse employment decisions").
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