Gerner v. County of Chesterfield, No. 11-1218
Decided Mar. 16, 2012
Karla Gerner brought this action against her former employer, Chesterfield County, Virginia, alleging that the County unlawfully discriminated against her by offering her a less favorable severance package than that offered male employees holding similar petitions. The district court dismissed the action on the grounds that denial of severance benefits did not constitute an adverse employment action. The Fourth Circuit reversed, holding that discriminatory denial of a non-contractual employment benefit constitutes an adverse employment action.
-Sara I. Salehi