Minor v. Centocor, Inc.
United States Court of Appeals for the Seventh Circuit
457 F.3d 632 (7th Cir. 2006)
M. Jane Minor (plaintiff), a sales representative for Centocor, Inc. (defendant), claimed her new supervisor increased her workload by 20 to 40 hours per week, causing her health problems, and sued under Title VII for age and sex discrimination. The district court granted Centocor summary judgment, reasoning Minor failed to make a prima facie showing of discrimination because she was never fired or demoted and the challenged conduct (increased workload, criticism, and closer oversight) amounted to routine aspects of employment rather than an "adverse employment action." Minor appealed.
Whether an employee is legally required to show an adverse employment action to succeed on a claim under Title VII of the Civil Rights Act, 42 U.S.C. § 2000e.