Read the following excerpt from a US court opinion:
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dismissed on June 20, 2009. Both actions were consolidated on June 24, 2009. 3 . The district court dismissed Cooper's Title VII race discrimination claims concerning his transfer to Harvey as barred because Cooper’s EEOC charge addressing those claims was untimely filed. The district court did analyze Cooper’s adverse employment action claims under § 1981, noting that the Title VII framework was equivalent. Cooper does not challenge the dismissal of his Title VII race discrimination claims concerning his transfer to Harvey, and accordingly, we do not review the district court's dismissal of those claims. However, we do evaluate, as the district court did, Cooper’s § 1981 claims concerning his transfer to Harvey. 4 . Cf. Keeton v. Flying J, Inc., 429 F.3d 259, 265 n. 2 (6th Cir.2005) ; Policastro v. Nw. Airlines, Inc., 297 F.3d
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What is the most suitable continuation to the opinion? Your options are:
A. holding that termination is an adverse employment action
B. holding that denial of a bonus was not an adverse employment action
C. holding that where an employee was transferred to a new job site over 120 miles away that transfer while not per se an adverse employment action was an appropriate factor for the jury to consider in determining whether an adverse employment action occurred
D. holding that a transfer of job duties can constitute an adverse employment action
E. holding that a transfer to a worksite 180 miles away from plaintiffs home did not necessarily constitute an adverse employment action while noting that such a transfer could under some circumstances constitute an adverse employment action
Reply with [A, B, C, D, E] only.