With no explanation, chose the best option from "A", "B", "C" or "D". connection[ ]’ [by showing] that engaging in the protected activity was a substantial or motivating factor in the adverse employment action.” Grady v. Shawnee Pub. Sch. Dist. I-93, No. 98-6099, 1998 WL 852533, at *5 (10th Cir. Dec.10, 1998)(unpublished decision)(citing Mt Healthy City Sch. Dist Bd. of Educ. v. Doyle, 429 U.S. at 287, 97 S.Ct. 568). “[E]mployers’ acts short of dismissal may be actionable as First Amendment violations, [however the Tenth Circuit has] never ruled that all such acts, no matter how trivial, are sufficient to support a retaliation claim. ... [T]here may be some minor adverse actions that would not constitute First Amendment violations.” Lybrook v. Members of the Farmington Mun. Schs. Bd. of Educ., 232 F.3d at 1340 (internal citations and quotations omitted)(<HOLDING>). “An employee alleging retaliation must show

A: holding that placing a teacher on a professional development plan which required the teacher to strive to create a collaborative atmosphere and act with high professional standards did not constitute an adverse employment action for purposes of first amendment retaliation
B: holding that the plaintiffs placement on paid administrative leave constituted an adverse action for purposes of a first amendment retaliation claim
C: recognizing retaliation involving promotion as adverse employment actions under the first amendment
D: holding that the administrative transfer of a teacher which denied him the opportunity to teach his preferred subject could constitute an adverse employment action
A.