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Transfer to a new position, without more, is not an adverse employment action.

October 1, 2010
Robinson v. Newark School Dist., Docket No. A-2345-08T2 (App. Div. August 26, 2010)

The plaintiff, a teacher, alleged that after engaging in whistle-blowing activity, she was transferred to another school. This was not considered a demotion, and the plaintiff did not suffer any loss of salary or benefits. The court concluded that the mere transfer could not be considered an adverse employment action.

Case Law Alert - 4th Qtr 2010

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