Voluntary return to lesser position must be prompted by “intolerable” conditions arising out of discriminatory motives.

A female employee who was promoted to a supervisory position but who volunteered to return to the production line four years later was not constructively demoted in violation of Title VII because she failed to show that “her multiple minor grievances and two substantive complaints created an intolerable work environment,” the U.S. Court of Appeals for the Seventh Circuit held Nov. 18 (Simpson v. Borg-Warner Automotive Inc., 7th Cir., No. 99-1048, 11/18/99).

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