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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

Rolfs v. Home Depot U.S.A., Inc., 971 F. Supp. 2d 197 (2013)

Citation
Rolfs v. Home Depot U.S.A., Inc., 971 F. Supp. 2d 197 (2013)
Parent Document
Rolfs v. Home Depot U.S.A., Inc., 971 F. Supp. 2d 197 (2013)
Jurisdiction
New Hampshire (state)
Effective Date
2013-09-20

Other Sections in This Document (163)

Full Text

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In sum, Rolfs’ own conduct undermines any argument that the P/DNs were adverse employment actions for purposes of his retaliation claim. If the P/DNs were not adverse employment actions, then Rolfs’ first retaliation claim is reduced to an assertion that Kelly placed him on a PIP in retaliation for “Come on, Gene.”10 But, even if the P/DNs are also adverse employment actions, Rolfs faces an insurmountable problem in establishing the third element of his prima facie case, causation.