What constitutes a materially adverse employment action?

In Thomas v. Department of Corrections (2000) 77 Cal.App.4th 507, 511, the court noted that " '[w]ork places are rarely idyllic retreats, and the mere fact that an employee is displeased by an employer's act or omission does not elevate that act or omission to the level of a materially adverse employment action.' " The court continued, an adverse employment action must be "more disruptive than a mere inconvenience or an alteration of job responsibilities. A materially adverse change might be indicated by a termination of employment, a demotion evidenced by a decrease in

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wage or salary, a less distinguished title, a material loss of benefits [or] significantly diminished material responsibilities . . . .' [Citation.] The employment action must be both detrimental and substantial." (Ibid.; accord Malais v. Los Angeles City Fire Dept. (2007) 150 Cal.App.4th 350, 357 ["Not every change in the conditions of employment, however, constitutes an adverse employment action. ' "A change that is merely contrary to the employee's interests or not to the employee's liking is insufficient." . . .' "].)