Title VII of the Civil Rights Act of 1964 makes it unlawful to discriminate against any individual with respect to the terms and conditions of employment because of certain protected characteristics, including gender. In order to support a claim under Title VII, an individual must point to an “adverse employment action” that was taken again
The 3d U.S. Circuit Court of Appeals has upheld lower court’s summary judgment decision, finding that an individual who refused to complete an application without some guarantee that a particular individual would not participate in the hiring process could not support a claim of race discrimination. Murray v. Beverage Distribution Center, 3d Cir., No. 11-1938,
