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Personnel.

U.S. District Court

ADA- Americans with Disabilities Act

DISCRIMINATION

FREE SPEECH

RETALIATION

EQUAL PROTECTION

Greco v. County of Nassau 146 F.Supp.2d 232 (E.D.N.Y. 2001). A county corrections officer brought state and federal claims against county officials, alleging employment discrimination based on a perceived disability, retaliation, constitutional violations, and slander. The district court granted summary judgment for the defendants. The court held that the officer failed to state a prima facie case of discrimination based on disability, because the employer clearly perceived the officer as being able to perform abroad range of tasks, as shown by the variety of assignments the officer had received. The court found that the officer's "abysmal" attendance record at work was a legitimate non-retaliatory reason for giving the officer a poor performance evaluation. The officer had testified before a county legislature regarding overtime pay. (Nassau County Sheriffs Department, New York)

U.S. Appeals Court

RETALIATION

TRANSFERS

RACE DISCRIMINATION

AGE DISCRIMINATION

TITLE VII

Stutler v. Illinois Dept. of Corrections 263 F.3d 698 (7th Cir. 2001). A state corrections employee brought a [ss] 1983 action against her supervisor and her employer, alleging retaliation, and race and sex discrimination. The district court granted summary judgment in favor of the employer and supervisor, and the employee appealed. The appeals court affirmed, finding that the employee's lateral transfer to another department was not an "adverse employment action" because there was no evidence that the transfer decreased the employee's benefits or responsibilities in anyway. The court held that the transfer was not retaliatory because it was done to relieve tension between the employee and her supervisor, which had resulted from a breakdown of their friendship. The court also found that the supervisor's conduct- sending an email to her boss characterizing the employee's conduct as bizarre, telling the employee that she had to go, telling the employee that she would have to move to an unfinished reception area to work, asking the employee to return her key to the supervisor's office, and telling the employee that she could not forgive her for filing a lawsuit--did not rise to the level of "adverse employment actions" for the purpose of a retaliation claim under Title VII. (Illinois Department of Corrections)
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Article Details
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Publication:Corrections Caselaw Quarterly
Article Type:Brief Article
Geographic Code:1USA
Date:Nov 1, 2001
Words:372
Previous Article:Mental problems (Prisoner).
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