Is dissemination of an unfavorable job reference an adverse employment action?

Similarly, in Hashimoto v. Dalton, 118 F.3d 671, 676 (9th Cir. 1997), we found that the dissemination of an unfavorable job reference was an adverse employment action "because it was a `personnel action' motivated by retaliatory animus." We so found even though the defendant proved that the poor job reference did not affect the prospective employer's decision not to hire the plaintiff: "That this unlawful personnel action turned out to be inconsequential goes to the issue of damages, not liability." Id.