Federal Court Holds That Written Reprimand Was Not Adverse Employment Action Sufficient to Support Retaliation Claim

The United States Court of Appeals for the Eighth Circuit, in Littleton v. Pilot Travel Center, LLC, held that a written reprimand, called a "Correction Notice," notifying an employee that if he did not discontinue his inappropriate and harassing conduct that he would be terminated was not an "adverse employment action" sufficient to support a retaliation claim. The Court reasoned that the Correction Notice was not "materially adverse" under the Burlington test because it did not "harmfully impact" his employment. A copy of the decision can be read here.

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