Written Warning Was Not an “Adverse Employment Action”; Race Discrimination Claim Dismissed
In Reid et al v. County of Erie, 2017 WL 4676833 (WDNY Oct. 16, 2017), the court dismissed plaintiff’s race discrimination case, finding that the “written warning” plaintiff received was not an “adverse employment action.” The court explained, inter alia, that (generally), “[n]egative performance evaluations, formal reprimands, and counseling memoranda are not adverse employment actions…
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