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4145 Employment action that materially affects the terms and conditions of employment may be found sufficiently adverse to result in liability under a Labor Code section prohibiting adverse employment action in retaliation for whistleblowing; for a middle school principal seeking to make her mark in a budding administrative career, transfer from a troubled school to the pristine confines of a high-achieving magnet school could be found to constitute an adverse employment action.CitationPATTEN v GRANT JOINT UHSD (Lateral Transfer) 134 CA4 1378 [See: LabC 1102.5; Horsford v Board of Trustees 132 CA4 359, T/AT 10/05; Yanowitz v L'Oreal 36 C4 1028, T/AT 4/03]
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