News Notes: Corrective Action Blocks Suit Over Negative Performance Review

The Ninth Circuit Court of Appeal has ruled that a negative performance evaluation didn’t support an employee’s retaliation claim because the employer promptly corrected the problem. Aybike Kortan, a clinical psychologist with the California Youth Authority, received a bad review after she complained about a supervisor’s harassment. The court said the poor review, while retaliatory, did no harm because a higher-level manager quickly revised it to “satisfactory” and removed the negative statement from her file.