In Davis v. Legal Services of Alabama, Inc. the United States Court of Appeals for the Eleventh Circuit addressed as a matter of first impression whether paid suspension constitutes an “adverse employment action” under 42 U.S.C. § 1981 and Title VII of the Civil Rights Act. Plaintiff-Appellant Artur Davis (“Davis”), a Black man, was suspended from his position with Legal Services of Alabama (“LSA”) with pay pending an investigation into complaints from other employees. Davis sued LSA for racial discrimination, claiming that his suspension with pay constituted an adverse employment action under 42 U.S.C. § 1981 and Title VII. The Eleventh Circuit held that suspension with pay pending an investigation is not an adverse employment action and affirmed the district court’s grant of summary judgment in favor of LSA.
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