Read the following excerpt from a US court opinion:
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course did not materially alter the terms and conditions of plaintiffs employment and therefore plaintiff could not recover under Title VII for such conduct). “To hold otherwise would be to expand the definition of ‘adverse employment action’ to include events such as disciplinary filings, supervisor’s reprimands, and even poor performance by the employee — anything which might jeopardize employment in the future. Such expansion is unwarranted.” Mattern, 104 F.3d at 708 (emphasis in original). Similarly, Reno’s other asserted incidents of retaliation are equally lacking in consequence. Humiliation experienced by Reno as a result of Moorer’s derogatory comments does not constitute an ultimate employment decision. See Spring v. Sheboygan Area Sch. Dist., 865 F.2d 883, 886 (7th Cir.1989) . Neither does Moorer’s unfulfilled threats to
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What is the most suitable continuation to the opinion? Your options are:
A. holding that in the first amendment employment context harassing speech must constitute constructive adverse employment action to be actionable
B. holding that termination is an adverse employment action
C. holding that cancellation of benefit to honor plaintiff in retaliation for filing an age discrimination complaint constitutes adverse employment action because of public humiliation involved
D. holding that conduct causing public humiliation was not an actionable adverse employment action because public perceptions were not a term or condition of employment of the plaintiffs employment
E. holding that denial of a bonus was not an adverse employment action
Reply with [A, B, C, D, E] only.