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| NEGATIVE EVALUATIONS NOT ADVERSE EMPLOYMENT ACTION |
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| A black police officer claimed discrimination after receiving two negative "counseling memos." One memo was removed and the other memo would not impact the employees' overall employment rating or pay increase. The Court wrote that the "loss of prestige or self-esteem felt by an employee who received what he believes to be unwarranted job criticism or performance review will rarely-without more-establish the adverse action necessary to pursue a claim under Title VII's anti-discrimination clause." |
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| (Davis Lake Park, Fla.) |
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