4th Circuit: No Adverse Action In Voluntary Transfer Sought By Employee

Mealey's (November 11, 2020, 10:44 AM EST) -- RICHMOND, Va. — A Virginia county worker who sought and achieved a transfer after the accommodations for her condition in her previous position became unsatisfactory failed to show an actionable adverse action, a Fourth Circuit U.S. Court of Appeals panel ruled Oct. 23 (Viola Laird v. Fairfax County, Virginia, No. 18-2511, 4th Cir., 2020 U.S. App. LEXIS 33516)....