context: To make out a prima facie case of racial discrimination under the indirect method of proof, plaintiffs must (among other things) identify an adverse employment action.
citation_a.signal: see also
citation_a.identifier: 245 F.3d 1232, 1238-39
citation_a.parenthetical: noting that courts have talked about materiality in different ways but noting that to qualify as a change to "terms, conditions, or privileges" of employment within Title VII's meaning requires an impact on plaintiffs job "in a real and demonstrable way"
citation_a.sentence: Griffin v. Potter, 356 F.3d 824, 829 (7th Cir.2004); see also Davis v. Town of Lake Park, 245 F.3d 1232, 1238-39 (11th Cir.2001) (noting that courts have talked about materiality in different ways but noting that to qualify as a change to “terms, conditions, or privileges” of employment within Title VII’s meaning requires an impact on plaintiffs job “in a real and demonstrable way”).
citation_b.signal: no signal
citation_b.identifier: 581 F.3d 575, 578
citation_b.parenthetical: burden-shifting analysis generally works the same under Title VII and SS 1981
citation_b.sentence: McGowan v. Deere & Co., 581 F.3d 575, 578 (7th Cir.2009) (burden-shifting analysis generally works the same under Title VII and § 1981). To qualify as adverse means materially adverse, “not merely an inconvenience or a change in job responsibilities.”