092587P.pdf   07/29/2010  Claudia Fercello  v.  County of Ramsey
   U.S. Court of Appeals Case No:  09-2587
   U.S. District Court for the District of Minnesota - Minneapolis   
   [PUBLISHED] [Melloy, Author, with Bye and Shepherd, Circuit Judges]
   Civil case - Employment Discrimination. Plaintiff failed to show she
   was functionally demoted in retaliation for reporting sexual harassment as
   the incidents she relied on to establish the demotion did not constitute
   materially adverse employment actions or were taken for legitimate, non-
   discriminatory reasons; negative performance reviews did not constitute
   retaliation; there was no evidence to support plaintiff's claims that oral
   warnings and uncivil treatment she received was retaliatory; plaintiff
   failed to show surveillance and time-tracking measures were imposed in
   retaliation for her report; plaintiff failed to establish a causal link 
   between her discharge at the end of probationary period and her protected 
   conduct and she failed to show the legitimate, non-discriminatory grounds 
   offered for the decision were pretexts for unlawful retaliation; plaintiff 
   failed to show she was constructively discharged.