William J. Ray v. William J. Henderson, Postmaster General

FLETCHER, Circuit Judge:

In this case we are called upon to determine whether William J. Ray suffered adverse employment actions after complaining of harassment at his workplace. We hold that in our circuit an adverse employment action is adverse treatment that is reasonably likely to deter employees from engaging in protected activity. Under this standard, we conclude that Ray suffered cognizable adverse employment actions when his employer, in retaliation for Ray’s complaints concerning management’s treatment of women employees, eliminated employee meetings, eliminated its flexible starting…