context: Second, it was not Dawkins himself who "wrote" Scott up -- as Dawkins was not Scott's superior -- but rather a captain. See Scott Dep. at 335. The complaint contains only allegations regarding Dawkins, however. Moreover, to the extent that Dawkins "assisted" a captain in "writing] her up" frivolously, this evidence alone is insufficient to show adverse action, as writing a reprimand for violating company policy does not itself constitute an adverse employment action.
citation_a.signal: cf.
citation_a.identifier: 548 U.S. 68, 68
citation_a.parenthetical: "An employee's decision to report discriminatory behavior cannot immunize that employee from those petty slights or minor annoyances that often take place at work and that all employees experience ... 'personality conflicts at work that generate antipathy' and 'snubbing by supervisors and co-workers are not actionable under SS 704(a
citation_a.sentence: See Cody v. County of Nassau, 577 F.Supp.2d 623, 645 (E.D.N.Y.2008) (defendant’s “falsely accusing plaintiff of being absent without authorization,” “threatening plaintiff with future counseling notices and disciplinary actions,” “writing plaintiff up for leaving work early,” and similar actions were not adverse employment actions); Nix v. Cino, 2006 WL 2711625, at *5 (E.D.N.Y. Sept. 21, 2006) (“Mere reprimands or threats of disciplinary action, absent any other negative results, such as a decrease in pay, do not qualify as adverse employment actions.”); cf. White, 548 U.S. at 68, 126 S.Ct, 2405 (“An employee’s decision to report discriminatory behavior cannot immunize that employee from those petty slights or minor annoyances that often take place at work and that all employees experience ... ‘personality conflicts at work that generate antipathy’ and ‘snubbing by supervisors and co-workers are not actionable under § 704(a).’ ”) (citations omitted).
citation_b.signal: see
citation_b.identifier: 577 F.Supp.2d 623, 645
citation_b.parenthetical: defendant's "falsely accusing plaintiff of being absent without authorization," "threatening plaintiff with future counseling notices and disciplinary actions," "writing plaintiff up for leaving work early," and similar actions were not adverse employment actions
citation_b.sentence: See Cody v. County of Nassau, 577 F.Supp.2d 623, 645 (E.D.N.Y.2008) (defendant’s “falsely accusing plaintiff of being absent without authorization,” “threatening plaintiff with future counseling notices and disciplinary actions,” “writing plaintiff up for leaving work early,” and similar actions were not adverse employment actions); Nix v. Cino, 2006 WL 2711625, at *5 (E.D.N.Y. Sept. 21, 2006) (“Mere reprimands or threats of disciplinary action, absent any other negative results, such as a decrease in pay, do not qualify as adverse employment actions.”); cf. White, 548 U.S. at 68, 126 S.Ct, 2405 (“An employee’s decision to report discriminatory behavior cannot immunize that employee from those petty slights or minor annoyances that often take place at work and that all employees experience ... ‘personality conflicts at work that generate antipathy’ and ‘snubbing by supervisors and co-workers are not actionable under § 704(a).’ ”) (citations omitted).