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| PERFORMANCE IMPROVEMENT PLAN NOT ADVERSE EMPLOYMENT ACTION |
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| A manager claimed age and gender discrimination after being assigned to a performance improvement plan. The Court found that the manager "cannot succeed on his claim of discrimination with respect to the Performance Improvement Plan because being required successfully to complete a plan is not an adverse employment action as a matter of law." |
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| (Cannon v. St. Paul Fire and Marine Ins. Co., N.D. Tex.) |
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