nonrenewal of [the plaintiffs] annual contract [to be] an adverse employment action”); Bleeker v. Vilsack, 468 Fed.Appx. 731, 732 (9th Cir.2012) (“Even inaction — a failure to renew or extend an employment contract — can count as an .adverse employment action in some circumstances.”); Leibowitz v. Cornell Univ., 584 F.3d 487, 501 (2nd 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 de 2d 955, 975 (W.D.Wis.2005) (“Defendant’s nonrenewal of [plaintiffs] contract constitutes an adverse employment action.”); but see Ewald v. Royal Norwegian Embassy, 2 F.Supp.3d 1101, 1120-21, No. 11-CV-2116 (SRN/SER), 2014 WL 896726, at *14 (D.Minn. Mar. 6, 2014) (<HOLDING>). In addition, at least one circuit has
holding that louisiana had jurisdiction over a modified contract of employment where the original employment contract was formed in texas but additional consideration for employment was negotiated in louisiana holding that a contract to sell real property was unenforceable because it did not contain a sufficient description of land subject to contract holding that employee handbook did not give rise to implied contract where it stated that it was not a contract and that employment was terminable at will holding that nonrenewal of threeyear contract that did not contain any provision for renewal was not a material employment disadvantage holding that no reporters record was required in suit to recover damages for breach of employment contract because the claim for damages was liquidated and proved by the employment contract attached to the petition