“Under this standard, Anderson has plausibly alleged that the PIP and her diminished role were adverse actions,” Judge Subramanian wrote. “These actions adversely affected Anderson’s benefits, privileges, terms, or conditions of employment by saddling her with more and worse tasks, tarnishing her permanent record, dampening her prospects of a promotion or raise, temporarily preventing her from transferring, excluding her from certain meetings and projects, and so on.”
The judge said Anderson’s PIP could also support her retaliation claim because it’s possible that being put on the plan would discourage a reasonable worker from complaining about discrimination.
However, Judge Subramanian tossed Anderson’s claims of a hostile work environment and constructive discharge, concluding that diminished responsibilities and occasionally unsupportive, rude or demanding bosses weren’t enough to sustain the allegations.
Anderson filed suit against Amazon and two Amazon Music executives in September. Judge Subramanian dismissed the executives from the suit Friday, saying Anderson failed to demonstrate that the court had jurisdiction over the out-of-state defendants.
