3987 REVIEW GRANTED Retaliatory conduct by an employer does not constitute "adverse employment action" unless it results or is likely to result in substantial and tangible harm to plaintiff's employment; a letter of instruction directing plaintiff to familiarize herself with her employment obligations was not adverse employment action; a public entity's decision to suspend plaintiff's was not adverse employment action because it was never put into effect and because it was not sufficiently final since it would have been subject to plaintiff's right of administrative review; transfer of a Department of Corrections employee to another employment location within the state's prison system was not an adverse employment action because it did not result in demotion, reduction in pay, loss of benefits, change in status, a less distinguished title, or any significant change in job responsibilities or commute time, and was not shown to subject plaintiff to any greater danger than she faced at her original employment location.

MCRAE v DEPT OF CORRECTIONS (Prison Doctor) 127 CA4 779 [See: GovC 12940; LabC 1102.5; Thomas v Dept of Corrections 77 CA4 507, T/AT 2/00; Akers v County of SD 95 CA4 1441, T/AT 3/02; Ray v Henderson 217 F3 1234]