With no explanation, chose the best option from "A", "B", "C" or "D". (5) low performance evaluations, (6) placement on indefinite paid leave, and (7) failure to advise him of meetings. Docs. ## 127,132,137. The Ninth Circuit has held that “not every employment decision amounts to an adverse employment action,” explaining that “only non-trivial employment actions that would deter reasonable employees from complaining about Title VII violations” are actionable. Brooks v. City of San Mateo, 229 F.3d 917, 928 (9th Cir. 2000); Vasquez v. County of Los Angeles, 349 F.3d 634, 651 (9th Cir.2003). Termination, negative employment references, undeserved negative performance reviews, and denial of promotions qualify as ' adverse employment actions. See Brooks, 214 F.3d at 1093; but see Kortan v. California Youth Authority, 217 F.3d 1104, 1112-13 (9th Cir.2000) (<HOLDING>); Lyons v. England, 307 F.3d 1092, 1118 (9th

A: holding that adverse employment actions include poor evaluations
B: holding that poor evaluations alone do not constitute an adverse employment action
C: holding that mediocre performance evaluations  rather than subaverage  that did not give rise to any further negative employment action did not constitute adverse actions
D: holding that a negative performance evaluation on its own is insufficient to constitute an adverse employment action as a matter of law
C.