In Blakes v. City of Hyattsville, 909 F. Supp. 2d 431 (D. Md. 2012), the plaintiff, a former police officer who resigned, contended he was constructively discharged and filed suit alleging a variety of employment claims based on two internal investigations the defendant conducted of him. The first involved an allegation that he may have helped an officer cheat on a promotional exam; the investigation found no impropriety. The second involved an allegation of excessive force by another officer at a shopping mall. Although he was not involved in the investigation of that allegation, the plaintiff persuaded a mall security officer to give him a copy of a security video. The plaintiff was then investigated for interfering with an official police investigation and behaving in a manner unbecoming of a police officer. The City suspended the plaintiff with full pay and subsequently filed administrative charges against him. Prior to the scheduled hearing, the plaintiff accepted a settlement offer and resigned. The court dismissed the plaintiff’s race discrimination claim under Title VII on the basis that the internal investigations did not constitute adverse employment actions. Citing principally Maryland precedents, the court stated that “although an investigation of an employee may constitute an adverse employment action in certain circumstances, disciplinary investigations ‘reasonably rooted in articulable facts justifying such an action’ typically do not rise to the level of adverse employment actions.” Here, the court found that a reasonable juror could only conclude that the two investigations were reasonably rooted in articulable facts, and thus granted summary judgment in favor of the City.