Second Circuit: Pecuniary Injury Not Necessary for “Adverse Action” for Retaliation Claim
A Summary Order issued today by the Second Circuit (in Kirkweg v. New York City Department of Education) includes language helpful to plaintiffs asserting retaliation claims. Citing the Supreme Court’s decision in Burlington N. & Sante Fe Ry. Co. v. White, 548 U.S. 53, 68−70 (2006) and Second Circuit precedent, the Second Circuit explains: In granting dismissal,…
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