looks less like adverse action and more like neutral passivity- 4 . Moreover, because Reed worked that day, the most she could have lost by not joining the ERT was the difference between one day's pay and one day’s overtime pay. Such a difference could well be described as a de minimus loss of pay, which does not rise to the level of adverse action. See Walker v. Thompson, 214 F.3d 615, 629 (5th Cir.2000). 5 . This is an entirely plausible assumption. An employer’s unforeseen mandate that an employee work overtime whenever the employer requires it could affect the "terms, conditions, or privileges" of employment, Brody, 199 F.3d at 457 (emphasis added), and thus could be described as adverse employment action. See, e.g., Kang v. U. Lim Am., Inc., 296 F.3d 810, 818-19 (9th Cir.2002) (<HOLDING>). 6 . Indeed, Reed does not contend that she
holding that the plaintiffs reports of his fellow police officers discriminatory treatment of minority citizens was not protected activity under title vii recognizing that the test for intentional discrimination in suits under  1981 is the same as the formulation used in title vii discriminatory treatment cases holding that noneconomic injury resulting from a hostile environment based on discriminatory sexual harassment is actionable under title vii holding that title vii claims of disparate treatment based on discriminatory overtime survive summary judgment holding claims based on title vii subject to arbitration