knew that plaintiffs cooperated with the special prosecutor or testified before the grand jury, and that any retaliation that occurred after plaintiffs' December 2004 hostile work environment letters did not rise to the level of an adverse employment action. The only suggestion by defendants of an argument even resembling the majority’s harmless error analysis is their statement, in a footnote, that "the jury verdict in Cachopa's favor in Trial Two further supports the reasonableness of the Court's entry of a Directed Verdict in Trial One.” 12 . The court acknowledged that Earle provided evidence of other more trivial confrontations with police, such as being stopped for alleged traffic violations, but concluded that no jury could have found that any of these incidents co 6th Cir.1995) (<HOLDING>); Dixon v. City of Lawton, 898 F.2d 1443, 1449
holding that even if court erred in directing verdict for employer on plaintiffs state law retaliation claim it was harmless given the jurys finding for employer on identical federal law retaliation claim holding that directing a verdict for employer on claim for willful violation of adea was harmless error because given jurys rejection of underlying adea claim it could noi have found willful violation of adea holding before the amendment providing the adea with extraterritorial force see note 2 ante that an adea claim by an american employee against an american employer was properly dismissed because the employee lived and worked overseas holding that plaintiff could not look to the courts for relief because he did not exhaust his administrative remedies under the adea holding that attorneys fees under adea may not be recovered against a defendant who was not an employer of the plaintiff