it was reasonably foreseeable that the Wells Memo would cause a punitive act to be taken against King significant enough to be classified legally as "adverse.” The Wells Memo did not need to contain "code words” to signal Harry to increase King’s security, nor does it matter that Harry herself was not subjectively alarmed by the words in Wells’s Memo because the causal chain did not stop at Harry. We also do not agree that transfers may never be adverse actions, although we take no issue with the prior holding in this case that King's transfer was not adverse. See Hill v. Lappin, 630 F.3d 468, 474-75 (6th Cir.2010) (collecting cases). Here, Wells's Memo outli usation not broken when false statements by retaliator caused innocent employer to fire plaintiff); Sykes, 625 F.3d at 311-12 (<HOLDING>). As we further explained, to hold otherwise
holding officers proximately caused malicious prosecution even though innocent party made the decision to prosecute holding that the defendant became the prevailing party and thus properly claimed attorneys fees when the plaintiffs claim was involuntarily dismissed for failure to prosecute holding clients independent voluntary decision to dismiss products liability suit precluded finding that attorneys alleged negligent preparation of case proximately caused clients injury holding that a party who cannot satisfy the requirements of the innocent landowner defense set forth in  9607b cannot maintain a  9607a claim against another prp even if they are   innocent in the common sense meaning of that word  holding that statutory damages are unavailable under the utpcpl in the absence of an ascertainable loss of money or property proximately caused by the defendants prohibited conduct