Jones v. Southeastern Pennsylvania Transportation Authority

OPINION OF THE COURT

HARDIMAN, Circuit Judge.

In this appeal, we consider whether a suspension with pay constitutes an “adverse employment action” under the substantive discrimination provision of Title VII. We hold that it typically does not.

I

Michelle Jones was fired in 2011 by her employer, the Southeastern Pennsylvania ' Transportation Authority (SEPTA). SEPTA says it dismissed Jones for submitting fraudulent timesheets; Jones says her termination was the culmination of years of unlawful sexual harassment, gender discrimination, and retaliation. The District Court entered judgment for SEPTA,…