In Eldridge v. Rochester City School District, 968 F. Supp. 2d 546 (W.D.N.Y. 2013), a schoolteacher brought an action against the school district for employment discrimination and for retaliation under 42 U.S.C. § 1983 for having complained about discrimination.  The plaintiff alleged that in September 2011, when she returned to school after the summer break, her name had been removed from her mailbox and she was not issued a key to her classroom, and that Caucasian employees were not subject to the same treatment.  She also alleged she began to receive “harassing emails” from the principal concerning her non-attendance at meetings.  She further alleged that in December 2011, the principal told her another teacher had accused her of harassment, and in February 2012, he informed her she was being investigated for racial harassment by an experienced investigator with the county sheriff’s office.  The principal then threatened her that they would not be working in the same school together the following year, but if she would agree to a transfer to another school, the harassment investigation would  cease.  On a motion to dismiss, the district court dismissed plaintiff’s equal protection claims on the basis that the internal investigation and alleged threats did not amount to an adverse employment action for equal protection purposes, but denied the motion to dismiss the retaliation claim.  Accepting the complaint’s allegations as true, including the condensed time period in which the events occurred, the court found that the plaintiff became the subject of an internal investigation shortly after she complained about discrimination and that “the pressure of an internal investigation, coupled with a veiled threat of an involuntary transfer, could dissuade a reasonable employee from engaging in protected activity.”  The court thus found that the plaintiff had sufficiently alleged an adverse employment action for purposes of the Section 1983 retaliation claim.