by assigning DiMeglio to a geographic subset of the very region from which he formerly had derived his zoning assignments; there was no change in his general duties, pay, benefits, or perquisites of office. Because this action is less severe than those adverse actions recognized by the Supreme Court in Rutan, it was not clearly established in December 1990 that Haines’ reassignment of DiMeglio’s job responsibilities rose to the level of a constitutional deprivation. The alleged reprimand that Haines directed at all the zoning inspectors was even more innocuous and certainly not clearly an actionable adverse employment action. Even today, the equivalent of Haines’ action likely would not be sufficiently adverse to implicate the First Amendment. See ACLU of Md., 999 F.2d at 785-86 (<HOLDING>); Dorsett v. Board of Trustees, 940 F.2d 121,
holding that the burning of an american flag is conduct sufficiently imbued with elements of communication to implicate the first amendment holding that ban on unauthorized practice of law did not implicate the first amendment holding that withdrawal of aclus paralegals contact visits with inmates even if retaliatory was not sufficiently adverse to the aclu to implicate first amendment right to petition holding that mere negligence does not implicate the right to due process holding that retaliatory discharge is a clearly established first amendment violation