Laura Akers, a deputy district attorney for San Diego County, had an excellent reputation for her work in the El Cajon domestic violence unit. But after Akers became pregnant, she was transferred to a misdemeanor unit. When she complained, her next performance review called her incompetent, inefficient and dishonest. Akers sued the county for gender bias and retaliation. The discrimination charge was dismissed, but a jury awarded Akers $150,000 on the retaliation charge. Now a California appeals court has upheld the jury’s verdict. Although a negative performance evaluation alone doesn’t usually amount to an adverse employment action, the court said there was sufficient evidence in this case that the negative review would preclude promotional opportunities for Akers.