A paid suspension “typically” does not constitute an “adverse employment action” under the substantive provision of Title VII of the Civil Rights Act (Section 703), the federal appeals court in Philadelphia has held in a case of first impression for the circuit, joining other courts that have ruled on the issue. Jones v. SEPTA, No. 14-3814, 2015 U.S. App. LEXIS 14094 (3d Cir. Aug. 12, 2015). The Court, however, declined to address whether a paid suspension could constitute an adverse employment action in the retaliation context under Title VII (Section 704). The Third Circuit has jurisdiction over Delaware, New Jersey, Pennsylvania, and the U.S. Virgin Islands.
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