Does the mere investigation of an employee constitute a sufficient adverse employment action for purposes of Title VII retaliation?

MultiRegion, United States of America

The following excerpt is from Campbell v. State, 892 F.3d 1005 (9th Cir. 2018):

3 As addressed below, merely investigating an employee might be a sufficient adverse employment action for purposes of a Title VII retaliation claim. See Lakeside-Scott v. Multnomah County , 556 F.3d 797, 803 n.7 (9th Cir. 2009) ; Poland v. Chertoff , 494 F.3d 1174, 1180 (9th Cir. 2007).

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