Murphy v. Wisconsin Parole Commission

How courts have described this case

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

• concluding that “reprimands without collateral consequences are akin to non-actionable: snubbing, antipathy, and petty slights” and “cannot be characterized as ‘adverse.’”
• noting that “a ‘materially adverse action,’ not ‘adverse employment action,’ is the proper articulation of the adversity element in retaliation claims”
• discussing Burlington N. & Santa Fe Ry. Co. v. White, 548 U.S. 53, 68-69 (2006)
• finding as to a Title VII claim that a reprimand without collateral consequences requires dismissal under the materially adverse action standard
• finding an adverse employment action when a verbal warning “will exacerbate future discipline in a way that plausibly can be expected to create a future adverse employment effect”
• collecting cases from within the Fourth Circuit for the proposition that “a reprimand without collateral consequences is so marginally adverse that it qualifies as neither ‘materially adverse’ nor [an] ‘adverse employment action.’”

Source: CourtListener parenthetical corpus (CC0).