In a recent case out of the United States District Court for the Eastern District of Pennsylvania, the Court found that a mere change in a title and some work duties was not an adverse employment action.
The former employee in Fiorentini v. William Penn School District, No. 13-3689 (E.D.Pa. 2016), who was battling cancer, was “demoted” from the role of full-time literacy coach to a combination literacy coach/reading specialist, with the new assignment requiring lower qualifications and working with a smaller number of students. It was explained by the school district that the change was done in preparation for the PSSA, a statewide standardized testing of student’s reading skills.
It is important to note that the teacher’s formal job title in her employment records and her salary were not changed. However, the employee argued that the change made her appear “less accomplished” and that other might perceive that she was “performing less prestigious tasks.”
However, the Court found that the change in type of work, fear of harm to reputation and the change in the title were not enough to make this an adverse employment action and dismissed her suit. It is unclear if the Court would have ruled differently if the employee’s formal job title had been changed, but it appears the argument could be made that it would not.
As a result, one’s job title probably isn’t worth that much and purported effect on one’s reputation due to a change in duties is likely of minimal value as well.
The Eastern Pennsylvania Employment Log (EPELog) is a publication of the KingSpry Employment Law Practice Group. Jeffrey T. Tucker, Esquire, is our editor-in-chief. EPELog is meant to be informational and does not constitute legal advice.
