Hyson v. Architect of the Capitol

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• concluding that a letter of counseling that warned “if this happens again, we will take the appropriate action” was not an adverse action because “the memorandum itself made clear that disciplinary action was not forthcoming” (alteration in original accepted)
• commenting that letters of counseling “will rarely constitute [] adverse action until Title VII”
• gathering cases in this district finding letters of reprimand insufficient to constitute a materially adverse action even under the more lenient standard for adverse actions in retaliation claims
• “A letter of counseling ... if not abusive in tone or language or a predicate for a more tangible form of adverse action, will rarely constitute materially adverse action under Title VII.”
• “A letter of counseling, written reprimand, or unsatisfactory performance review, if not ... a predicate for a more tangible form of adverse action, will rarely constitute materially adverse action under Title VII.” (emphasis added)
• “A letter of counseling, written reprimand, or unsatisfactory performance review, if not abusive in tone or language or a predicate for a more tangible form of adverse action, will rarely constitute materially adverse action under Title VII.”

Source: CourtListener parenthetical corpus (CC0).