EMPLOYER DISCRIMINATION; ADVERSE ACTIONS – Warning Letters, Reprimands, Evaluations

Single Topic for Decision 2265E

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PERB has found that not all verbal expressions of concern about an employee’s conduct rise to the level of a verbal reprimand for purposes of determining whether there has been an adverse action; where charge alleged that the respondent offered suggestions regarding curriculum issues after “implying” that there were student complaints regarding charging party’s teaching techniques, the respondent’s actions cannot be found to be adverse under an objective standard.