whether the nonrenewal of a term appointment can constitute an adverse action for purposes of Title VII and the ADEA”), other circuits increasingly recognize such claims, see, e.g., Leibowitz v. Cornell Univ., 584 F.3d 487, 501 (2d Cir.2009) (“An employee seeking a renewal of an employment contract, just like a new applicant or a rehire after a layoff, suffers an adverse employment action when an employment' opportunity is denied and is protected from discrimination in connection with such decisions”) (collecting cases); Wilkerson v. New Media Tech. Charter Sch. Inc., 522 F.3d 315, 320 (3d Cir.2008) (“The failure to renew an employment arrangement, whether at-will or for a limited period of time, is an employment action”); Carter v. Univ. of Toledo, 349 F.3d 269, 270-71 (6th Cir.2003) (<HOLDING>); Minshall v. McGraw Hill Broad. Co., 323 F.3d
recognizing failure to renew contract as adverse action holding that failure to renew a contract and failure to hire for a new position were discrete acts of discrimination pursuant to morgan holding that termination is an adverse employment action holding in title vii case that plaintiff demonstrated adverse employment action in school districts decision not to renew principals contract for the following year but offering principal a demotion recognizing that unequal pay is an adverse action