An “adverse employment action” under any of the federal employment laws can take many forms. In the decision of Cashman v. CNA Financial Corp. , the U.S. District Court for the Eastern District of Pennsylvania addressed whether a poor evaluation, followed by a performance improvement plan and, ultimately, a refusal to rescind an employee’s resignation, amounted to the type of adverse action sufficient to support various discrimination claims.

Leave for Cancer Treatment

John Cashman was a long-term claims investigator and team leader for CNA when he was diagnosed with bladder cancer in the spring of 2004. He took leave for treatment at the time and returned to work a few months later, according to the opinion.