Kuhn v. Washtenaw County, 709 F.3d 612 (6th Cir. 2013), arose out of a traffic stop after which the driver accused a sheriff’s deputy of raping her. An internal investigation was initiated into the allegation. The allegation was quickly shown to be false, but due to a series of mishaps it took the sheriff’s office a number of months to conclude the investigation. The deputy began to seek treatment for stress and subsequently took leave pursuant to the Family and Medical Leave Act. He was then granted additional discretionary leave but was eventually required to return to work. When he refused, he was terminated. He sued the county on a variety of theories, one of which was that the initiation of the internal investigation was racially discriminatory. The district court rejected that theory on the basis that initiation of an internal investigation is not an adverse employment action. On appeal, the deputy argued that an internal investigation can constitute an adverse employment action if initiated in bad faith. The court of appeals held that there was no evidence of bad faith, considering that the investigation was required under department policy, and additionally noted that the deputy had not cited any authority for the proposition that bad faith initiation of an internal investigation constitutes an adverse employment action. A separate claim by the deputy against his supervisor claiming that the investigation constituted intentional interference with contract was rejected because the deputy had not shown the supervisor to be motivated solely by his own benefit; the supervisor thus did not qualify as a third party as required for an intentional interference claim. Therefore, the court of appeals affirmed summary judgment in favor of the county.