Reviewing the standard for retaliation in employment discrimination cases under Title VII of the Civil Rights Act of 1964, which prohibits employment discrimination based on race, color, religion, sex and national origin. DECIDED

The plaintiff in this case was suspended without pay for more than a month and reassigned to a less desirable position after she complained of workplace discrimination. The question is whether those actions constitute retaliation under Title VII even though the plaintiff ultimately won her grievance.

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