What is the test for an adverse employment action where an employee does not show that their new duties are less significant than their previous ones?

MultiRegion, United States of America

The following excerpt is from Galabya v. NYC Bd. Education, 202 F.3d 636 (2nd Cir. 1999):

responsibilities was not an adverse employment action where employee did not show that the new duties were "less significant" than the previous ones); Ticali v. Roman Catholic Diocese of Brooklyn, 41 F. Supp. 2d 249, 265 (E.D.N.Y 1999) (notwithstanding teacher's "disdain" for new assignment, her transfer to pre-kindergarten class from first grade class was not an adverse employment action because teacher produced "no material evidence that her transfer obliged her to perform tasks that were less appropriate for her skills than her prior position or adverse to her in any other legally cognizable way") (citing Cooper v. New York State Dep't of Human Rights, 986 F. Supp. 825, 828 (S.D.N.Y. 1997)).

III. Conclusion

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