What is the test for an adverse action against a government employer for making threats against a civil servant?

In determining whether conduct amounts to an adverse action, the court asks whether "the exercise of the first amendment rights was deterred" by the government employer's action." Coszalter v. City of Salem, 320 F.3d 968, 975 (9th Cir. 2003) (internal citations and quotation marks omitted). To be considered an adverse action, Plaintiffs must "demonstrate the loss of a valuable government benefit or privilege.. .mere threats and harsh words are insufficient." Nunez v. City of Los Angeles, 147 F.3d 867, 875 (9th Cir. 1998)(internal citations and quotation marks omitted). In Nunez, the court held that verbal threats from fellow offers were not enough for the plaintiff's claims to "survive [the] threshold

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