United States Eighth Circuit

In a retaliation action against a county, plaintiff's former employer under Title VII, summary judgment for defendant is affirmed where: 1) the actions taken by the county supposedly constituting a "functional demotion" were not materially adverse employment actions; 2) even if defendant's performance review constituted materially adverse employment action, a reasonable jury could not find that it was causally related to plaintiff's harassment report; and 3) plaintiff did not put forth evidence that the time-tracking procedures employed by defendant were implemented in any part because of plaintiff's harassment report.

Appellate Information

• Decided 07/29/2010
• Published 07/29/2010

Judges

• Michael J. Melloy

Court

• United States Eighth Circuit

Counsel