Finally, the standard for employer liability under CEPA is lower than under § 1983, as New Jersey imposes re-spondeat superior liability upon employers. See Abbamont v. Piscataway Township Bd. of Educ., 138 N.J. 405, 420-21, 650 A.2d 958 (1994). The practical implication of these differences, in this case, is that some of the incidents supporting Plaintiffs’ free speech claims may not suffice to survive summary judgment under a CEPA theory. Most notably, Roberts Taylor’s claim that she was put “on the outs” with the heads of the City Attorney’s Office in retaliation for her objections to illegal contracts is not a sufficiently “adverse” act to be actionable under CEPA. Cf. Shepherd v. Hunterdon Developmental Ctr., 336 N.J.Super. 395, 415-16, 765 A.2d 217, 228-29 (App.Div.2001) (<HOLDING>). A closer question is whether Sunkett’s
holding that the conditions delineated in canon 3c1a alone would not be sufficient basis for imposing a constitutional requirement under the due process clause holding that the worker was entitled to full ttd benefits because the employer never made an offer of employment once the worker was released to work holding no jurisdiction to entertain prp citizen suit where suit if successful would dictate specific remedial actions and  alter the method and order for cleanup in violation of 113h holding that conduct that sporadically wounds or offends is not so egregious as to alter the conditions of employment and destroy womens equal opportunity in the workplace holding in suit under njlad that a supervisors decision to no longer socialize with a worker or be cordial would not alone alter the conditions of employment