Coszalter v. City of Salem

WILLIAM A. FLETCHER, Circuit Judge:

Plaintiffs, current and former employees of the City of Salem, Oregon, sued under 42 U.S.C. § 1983, alleging that defendants violated their First Amendment rights by retaliating against them for publicly disclosing health and safety hazards. The magistrate judge, hearing the case with the permission of the parties, granted defendants’ motion for summary judgment after finding that most of the alleged retaliatory acts were not adverse employment actions because they did not constitute “lossfes] of ... valuable benefit[s] or privilege[s],” and that retaliation…