action” is one that is “serious and tangible enough to alter an employee’s compensation, terms, conditions, or privileges of employment.” Cardenas v. Massey, 269 F.3d 251, 263 (3d Cir.2001) (quoting Robinson v. City of Pittsburgh, 120 F.3d 1286, 1300 (3d Cir.1997)). The Court cannot say, from the allegations of the amended complaint, that Amtrak’s alleged 2002 refusal to allow Ms. Seldon to work from home was too minor to constitute an adverse employment action. An employment decision need not result in a change in compensation or job title to constitute an adverse employment action. Torre v. Casio, Inc., 42 F.3d 825, 827, 831 n. 7 (3d Cir.1994). Job transfers to comparable positions in a less favorable location can form the basis of a discrimination claim. Jones, 198 F.3d at 411 (<HOLDING>). Similarly, failure to transfer an employee to
holding that a denial of transfer was not an adverse employment action where the plaintiff asserted only that the transfer would allow him to work closer to home holding that a transfer of job duties can constitute an adverse employment action holding that the administrative transfer of a teacher which denied him the opportunity to teach his preferred subject could constitute an adverse employment action holding that a transfer to a worksite 180 miles away from plaintiffs home did not necessarily constitute an adverse employment action while noting that such a transfer could under some circumstances constitute an adverse employment action holding that a lateral transfer without a loss in benefits does not constitute an adverse employment action