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Garland's Digest
on employment discrimination law
online since 1997
 

 

Disclaimer: The case on which this summary is based may no longer be current law. Also, if the case was decided on summary judgment, the court recited the "facts" in the light most favorable to the non-movant, which may not be the true facts.

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LePique v. Hove, 217 F.3d 1012 (8th Cir. May 31, 2000) - In this Title VII retaliation action, the Court holds that a denial of a lateral transfer is not an adverse employment action entitled to Title VII protection. The Court is following the recent case of Spears v. Missouri Dept. of Corrections and Human Resources, 210 F.3d 850 (8th Cir. April 28, 2000) in which the Court held that a transfer to a lateral position in another city is not an adverse employment action. Click here to see actual case.