Pregnant bank manager has no legal claim despite transfer to less desireable branch
Jacquetta Dantzler was named the Manager of the Grand Blanc branch of Morgan Chase Bank. Within weeks, and just after announcing she was pregnant, she was transferred to the South Flint branch. She thought the transfer was an illegal retaliation for her pregnancy. The trial court held it was not. On appeal, the Court of Appeals ruled that she had not a proved a "cat's paw" theory (meaning discrimination at the hands of one supervisor at the behest of another). The court further held that she had not suffered an injury under the statute that prohibits pregnancy discrimination. It ruled that to prove an adverse employment action, she would have needed to show termination, demotion evidenced by decrease in salary, a reduction in job title or a significant diminuition in job responsibilities. "Merely" being transferred to a more inconvenient or less desirable work location did not qualify.