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------------------------- A reassignment can only form the basis of a valid Title VII claim if the plaintiff can show that the reassignment had some significant detrimental effect. James v. Booz-Allen & Hamilton, Inc., 368 F.3d 371 (4th Cir. May 14, 2004) - This is a Title VII race discrimination action alleging constructive discharge. Aaron C. James, an African American male, was project manager for BAH's contract with the Washington Metropolitan Area Transit Authority (WMATA). In February of 1999, James was reassigned due to complaints about his work performance from his WMATA counterparts and based upon personal difficulties between him and his WMATA counterparts. However, he still performed duties consistent with his job description. He received a "highly effective" rating on his next annual evaluation. He also received a five percent salary increase and a $15,000 bonus. Nevertheless, he resigned from BAH a few months later. The district court granted summary judgment on behalf of BAH. The Fourth Circuit affirms because James failed to show that he was subjected to an adverse employment action. Click here to see actual case.
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