. . . there was a causal connection between the protected activity and the adverse employment decision[s].” Murray v. St. Michael’s Coll., 164 Vt. 205, 210, 667 A.2d 294, 299 (1995). In Burlington Northern, the Supreme Court held that a plaintiff bringing a retaliation claim under Title VII need show only that “a reasonable employee [in the employee’s situation] would have found the challenged action materially adverse,” meaning that it well might have dissuaded a reasonable employee from engaging in the protected activity. 548 U.S. at 68. ¶ 34. Assuming, without deciding, that this is the standard to apply with respect to retaliation claims brought under 21 V.S.A. § 710(b), we conclude that the limited video surveillance in this case in connectio v., 37 F.3d 1146, 1150 (5th Cir. 1994) (<HOLDING>). ¶ 35. But in this case, if the release
holding that the former wife did not waive her attorneyclient privilege simply because the credibility of her claim that she relied on her husbands representations could be impeached by deposing her former attorney holding that threatening employee to mind her own business investigating her videotaping her without her permission and forcing her to take polygraph could not be considered adverse employment actions because they had no effect on conditions of employment holding that because a claimant testified that she had no insurance and could not afford treatment her failure to take medication for her symptoms is not a clear and convincing reason for discrediting her symptom testimony holding that a teachers complaint to school authorities that her principal had instructed her to make improper changes in her own students grades was unprotected because it was made pursuant to her official duties holding that the employee was acting within the course of her employment when she died while returning from the workrelated session because her death occurred on a public highway which was brought within the scope of her employment by her employers requirement that she attend training at the state police academy