Madlock v. WEC Energy Group, Inc. 

Dist. Ct. did not err in granting defendant-employer’s motion for summary judgment in section 1981 action by plaintiff-employee alleging that her transfer from one section of defendant’s billing division to another was result of racial discrimination, and that defendant retaliated against her for filing internal discrimination complaint by issuing her written report. Plaintiff failed to establish sufficient adverse act arising out of instant transfer, where plaintiff suffered no reduction in salary, loss of benefits or loss of title, and plaintiff’s loss of team co-workers whom she previously served as lead worker was insufficient to constitute actionable adverse act, where plaintiff’s loss of leadership position through transfer was intended to be only temporary. Fact that some of plaintiff’s co-workers believed that plaintiff’s transfer was humiliating did not require different result. Also, plaintiff failed to establish prima facie case of retaliation based on disparate treatment, where plaintiff contended that defendant had not disciplined anyone else for committing workplace infraction months before issuance of discipline, and where plaintiff had failed to identify anyone else who committed infraction many months before management had learned of said infraction. Also, plaintiff presented no direct evidence suggesting that management ever responded negatively to her filing of internal discrimination complaint or took steps against her because of it.