With no explanation, chose the best option from "A", "B", "C" or "D". at River-view, and the District did not consider Garza’s transfer final until it consulted with Garza’s union. {Id. ¶¶ 67, 72.) Since Garza has not demonstrated that his transfer to Riverview affected his wages, benefits, or career prospects, his transfer is not a materially adverse employment action for purposes of his retaliation claim. And given the entirely reasonable explanation the District offered for transferring Garza instead of Schuldt, it doesn’t even amount to evidence of discrimination. Garza’s performance reviews also do not constitute materially adverse employment actions as a matter of law. A negative performance review, under some circumstances, could constitute a materially adverse action. See Silverman v. Bd. of Educ. of Chicago, 637 F.3d 729, 741 (7th Cir.2011) (<HOLDING>). However, the majority of courts in this

A: holding that negative perform anee evaluations of a teacher constituted a materially adverse employment action for purposes of a retaliation claim
B: holding that the plaintiffs placement on paid administrative leave constituted an adverse action for purposes of a first amendment retaliation claim
C: holding that a negative criticism or performance evaluation unaccompanied by a materially adverse change in the terms or conditions of employment does not constitute adverse employment action
D: holding that two counseling statements similar to negative performance evaluations do not rise to level of materially adverse employment action required under title vii
A.