Title VII

No Adverse Employment Action = No Claim for Retaliation

Posted on February 21, 2014

Where employee voluntarily quit her job at a restaurant in anticipation of a transfer to a different location that never came to fruition, she has not suffered an adverse employment action and thus has no claim for retaliation.   Last week, in Andrews v. CBOCS West, Inc., et al., No. 12-3339 (7th Cir. 2014), the Seventh Circuit ruled that Cracker Barrel was entitled to summary judgment where a waitress at Cracker Barrel had elected to quit with the idea that she would transfer to another location, despite her assertion of numerous unsavory facts regarding discriminatory conduct on the part of her supervisor (and a lack of responsiveness to complaints about this conduct from the company).…

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