EMPLOYER DISCRIMINATION; ADVERSE ACTIONS – Transfer, Promotion, or Demotion; Work Assignments and Opportunities

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Board found context highly relevant in determining that a reasonable employee would find requiring a teacher to attend professional development courses in which teachers shared lesson plans constituted an adverse action where the teacher was assigned to a “do nothing” position with no students and consequently had no lesson plans to share. In another context, non-punitive directives may not constitute adverse action. (Chula Vista Elementary School District (2018) PERB Decision No. 2586, p. 25, quoting Newark Unified School District (1991) PERB Decision No. 864, pp. 11-12.)