In the first case expanding the U.S. Supreme Court's recent decision in Burlington Northern v. White (2006) (addressing what constitutes an adverse employment action under Title VII) to a Family and Medical Leave Act (FMLA) case, a court in Arizona held that putting an employee on an involuntary paid leave was an adverse employment action in retaliation for requesting additional FMLA leave. See Foraker v. Apollo Group, Inc. (D. Ariz. 2006). The Arizona court stated that a reasonable employee likely would find such an administrative leave to be "materially adverse" as required by Burlington. The court held that the elimination of all job responsibilities, all contact with co-workers, all experience and education that would come from fulfilling one's job responsibilities, and all periodic performance reviews for an indefinite period of at least 12 months "well might have dissuaded a reasonable worker" from requesting FMLA leave.