A materially adverse employment action must be more disruptive than a mere inconvenience or an alteration of job responsibilities, such as a demotion, loss of benefits, or significant reduction in responsibilities.
An employee sued his former employer under the Age Discrimination in Employment Act after being transferred to a different position and subsequently terminated. The employee alleged that the transfer constituted a materially adverse employment action. To establish a prima facie case, an employee must show a materially adverse action, which must be more disruptive than a mere inconvenience or an alteration of job responsibilities. Such an action may include termination, demotion with a decrease in salary, a less distinguished title, a material loss of benefits, or significantly diminished responsibilities. Because the transfer involved no change in salary or benefits and the employee failed to prove the employer's claim of job abandonment was pretextual, the court held no material adverse action occurred.
At page 136 Defining materially adverse employment action standards540 citing cases“termination of employment, a demotion evidenced by a decrease in wage or salary, a less distinguished title, a material loss of benefits, significantly diminished material responsibilities, or other indices that might be unique to a particular situation.”
- Johnson-Carter v. B.D.O. Seidman, LLP, 169 F. Supp. 2d 924 (N.D. Ill. 2001).published But see Crady v. Liberty Nat’l Bank & Trust Co., 993 F.2d 132, 136 (7th Cir.1993).
- Mary Chambers v. DC (EN BANC), 35 F.4th 870 (D.C. Cir. 2022).published(a materially adverse change in the terms and conditions of employment must be more disruptive than a mere inconvenience or an alteration of job responsibilities)
- Shirley Hoffman v. Caterpillar, Inc., 256 F.3d 568 (7th Cir. 2001).published([A] materially adverse change in the terms and conditions of employment must be more disruptive than a mere inconvenience or an alteration of job responsibilities.)
- Forkkio v. Tanoue, 131 F. Supp. 2d 36 (D.D.C. 2001).published ([A] materially adverse change in the terms and conditions of employment must be more disruptive than a mere inconvenience or an alteration of job responsibilities.)
- Hammonds, No. 1:25-cv-00041 (N.D. Ind. Sept. 17, 2026).Co. of Indiana, 993 F.2d 132, 136 (7th Cir.1993)).
- Khan v. New York State Dep't of Health, No. 1:25-cv-00950 (N.D.N.Y. July 27, 2026).Examples of materially adverse actions include "'termination of employment, a demotion evidenced by a decrease in wage or salary, a less distinguished title, a material loss of benefits, significantly diminished material responsibilities,…
- Bravard, No. 1:24-cv-02228 (S.D. Ind. May 18, 2026).Under Seventh Circuit law, an adverse employment action must be material, meaning "more disruptive than a mere inconvenience or an alteration of job responsibilities." Crady v. Liberty Nat'l Bank & Trust Co., 993 F.2d 132, 136 (7th Cir. 19…
- Skalski, No. 1:23-cv-15370 (N.D. Ill. Mar. 27, 2026).An adverse employment action is “a materially adverse change in the terms and conditions of employment that is more disruptive than a mere inconvenience or an alteration of job responsibilities.” Stockett v. Muncie Indiana Transit Sys., 22…
- Kinder, No. 1:24-cv-00856 (S.D. Ind. Mar. 2, 2026).For example, a “materially adverse change might be indicated by a termination of employment, a demotion evidenced by a decrease in wage or salary, a less distinguished title, a material loss of benefits, significantly diminished material r…
- Andre L. Ibrahim v. Brian Johnson, et al., No. 4:25-cv-00369 (E.D. Tex. Feb. 9, 2026).Burlington Indus., Inc. v. Ellerth, 524 U.S. 742, 761 (1998) (citing Crady v. Liberty Nat’l Bank & Trust Co. of Ind., 993 F.2d 132, 136 (7th Cir. 1993), regarding termination); Beaumont v. Tex. Dep’t of Crim. Just., 468 F. Supp. 2d 907, 92…
Show 187 more citing cases
- Threlkeld, No. 3:22-cv-00439 (W.D. Ky. Dec. 5, 2025).A change in employment conditions “must be more disruptive than a mere inconvenience or an alteration of job responsibilities.” Kocsis v. Multi–Care Management, Inc., 97 F.3d 876, 886 (1996) (quoting Crady v. Liberty Nat’l Bank and Trust C…
- Hayes, No. 1:24-cv-00882 (W.D.N.Y. Sept. 26, 2025).“To be ‘materially adverse’ a change in 8 The record is ambiguous as to whether these alleged threats came from someone with supervisory or managerial authority over Plaintiff, and Defendant does not address the issue. 9 Defendant argues,…
- Morris v. Chicago Cent. Pac. R.R. Co., No. 1:21-cv-03723 (N.D. Ill. July 8, 2025).Ill. 2020) (citing Crady v. Liberty Nat'l Bank & Trust Co., 993 F.2d 132, 136 (7th Cir. 1993)).
- Jackson v. NYS Dep't of Labor, No. 1:18-cv-04220 (E.D.N.Y. Mar. 31, 2025).“A materially adverse change might be indicated by a termination of employment, a demotion evidenced by a decrease in wage or salary, a less distinguished title, a material loss of benefits, significantly diminished material responsibiliti…
- Simmons v. United Parcel Serv. Inc, No. 3:23-cv-01128 (N.D. Ala. Mar. 19, 2025).“Any adversity 13 must be material; it is not enough that a transfer[, or any other contested employment action,] imposes some de minimis inconvenience or alteration of [the terms, conditions, privileges, or] responsibilities [of the plain…
- Baumgartner v. City of Chicago, 759 F. Supp. 3d 868 (N.D. Ill. 2024).publishedAn adverse employment action is “a materially adverse change in the terms and conditions of employment [that is] more disruptive than a mere inconvenience or an alteration of job responsibilities.” Stockett v. Muncie Indiana Transit Sys.,…
- Rogers v. Voltron Data, Inc., No. 2024-0084 (D.D.C. Oct. 31, 2024).publishedBank & Trust Co. of Ind., 993 F.2d 132, 136 (7th Cir. 1993)).
- Johnson v. Ault, No. 2:24-cv-00050 (S.D. Ind. July 23, 2024).Id. at 575 (citing Crady v. Liberty Nat'l Bank & Trust Co., 993 F.2d 132, 136 (7th Cir. 1993)); see also Emerick v. Wood River—Hartford Sch.
- Lashawn Roberts v. Louisville & Jefferson Cnty. Metro. Sewer Dist., No. 2022 CA 001447 (Ky. Ct. App. May 9, 2024).unpublishedSuch actions “must be more disruptive than a mere inconvenience or an alteration [of] job responsibilities.” Kocsis v. Multi-Care Management, Inc., 97 F.3d 876, 886 (6th Cir. 1996) (quoting Crady v. Liberty Nat’l Bank and Trust Co., 993 F.…
- Williams v. Bd. of Educ., City of Chicago, No. 1:20-cv-00073 (N.D. Ill. Apr. 29, 2024).Co., 993 F.2d 132, 136 (7th Cir.1993)) (alteration in original).
- Stapleton v. Nestle, No. 1:17-cv-05589 (N.D. Ill. Apr. 2, 2024).(finding no adverse action where the change in an employee’s responsibilities was not less significant than his prior responsibilities)
- Diakite v. Dep't of Treasury, Sec'y of, No. 2:23-cv-10470 (E.D. Mich. Feb. 16, 2024).In Kocsis, the Sixth Circuit concluded that a “materially adverse employment action might be indicated if an employee received significantly diminished material responsibilities.” Kocsis, 97 F.3d at 886 (quoting Crady v. Livery Nat’l Bank…
- Allen v. Salt Lake Cnty., 713 F. Supp. 3d 1171 (D. Utah 2024).publishedAdditional examples include “a termination in employment, a demotion evidenced by a granted regardless of this assumption, however, because the court finds that Defendant County adequately proved each element of its Ellerth/Faragher defens…
- Alexander v. Lewis, No. 3:20-cv-00370 (D. Conn. Sept. 29, 2023).Such a materially adverse change “might be indicated by a termination of employment, a demotion evidenced by a decrease in wage or salary, a less distinguished title, a material loss of benefits, significantly diminished material responsib…
- Paul v. Cnty. of Madison, No. 5:22-cv-01111 (N.D.N.Y. Sept. 27, 2023).To meet this standard, “a change in working conditions must be ‘more disruptive than a mere inconvenience or an alteration of job responsibilities.” ld. (quoting Crady v. Liberty Nat'l Bank and Trust Co., 993 F.2d 132, 136 (7" Cir. 1993)).
- Roberts v. Verizon Wireless, No. 1:21-cv-02847 (D. Colo. Sept. 13, 2023).But although the term is not confined to, for example, “monetary losses in the form of wages or benefits [,] . . . ‘a mere inconvenience or an alteration of job responsibilities’” does not constitute an “adverse employment action.” Sanchez…
- Peck v. Cnty. of Onondaga, New York, No. 5:21-cv-00651 (N.D.N.Y. Sept. 6, 2023).To be “materially adverse,” the change must be “more disruptive than a mere inconvenience or an alteration of job responsibilities.” Id. (citing Crady v. Liberty Nat’l Bank and Trust Co., 993 F.2d 132, 136 (7th Cir. 1993)).
- Ghosh v. Capital One Servs., LLC, No. 1:21-cv-04111 (N.D. Ill. Aug. 2, 2023). Bank and Trust Co. of Indiana, 993 F.2d 132, 136 (7th Cir. 1993).
- Jackson v. United States, No. 3:22-cv-00263 (W.D. Ky. June 7, 2023).Co. of Indiana, 993 F.2d 132, 136 (7th Cir. 1993)).
- Hove, Nancy v. Pierce Cnty., No. 3:22-cv-00487 (W.D. Wis. Mar. 20, 2023). “A materially adverse change might be indicated by a termination in employment, a demotion evidenced by a decrease in wage or salary, a less distinguished title, a material loss of benefits, significantly diminished material responsibiliti…
- Hollington v. CDM Fed. Programs Corp., No. 1:22-cv-04940, 2023 WL 2457057 (S.D.N.Y. Mar. 10, 2023).“To be ‘materially adverse,’ a change in working conditions must be ‘more disruptive than a mere inconvenience or an alteration of job responsibilities.’” Id. (quoting Crady v. Liberty Nat’l Bank & Trust Co. of Ind., 993 F.2d 132, 136 (7th…
- Beverly v. Abbott Labs., No. 1:17-cv-05590 (N.D. Ill. Jan. 20, 2023).For a reduction of job responsibilities to be a materially adverse employment action, it “must be more disruptive than a mere inconvenience or an alteration of job responsibilities.” Crady v. Liberty Nat'l Bank & Trust Co., 993 F.2d 132, 1…
- Garcia v. Denver Health Med. Ctr., No. 1:22-cv-01651 (D. Colo. Jan. 3, 2023).Co. of Indiana, 993 F.2d 132, 136 (7th Cir. 1993)).
- Yeager v. Kohler Co, No. 2:22-cv-00065 (E.D. Wis. Nov. 28, 2022).Wis. Sep. 12, 2005) (quoting Crady v. Liberty Nat’l Bank & Trust Co., 993 F.2d 132, 136 (7th Cir. 1993)).
- Johnson-wiggins v. New Jersey Dep't of Human Servs./ancora Psychiatric Hosp., No. 1:20-cv-00802 (D.N.J. Nov. 15, 2022).Co., 993 F.2d 132, 136 (7th Cir. 1993).
- Milner-Koonce v. Albany City Sch. Dist., No. 1:21-cv-01271 (N.D.N.Y. Oct. 13, 2022).Bd. of Educ., 202 F.3d 636, 640 (2d Cir. 2000) (quoting Crady v. Liberty Nat'l Bank and Trust Co., 993 F.2d 132, 136 (7th Cir.1993)), abrogated on other grounds as recognized in Davis-Garett v. Urban Outfitters, Inc., 921 F.3d 30, 43-44 (2…
- Harris v. Charles E. Smith Life Communities, No. 8:21-cv-01242, 2022 WL 4777592 (D. Md. Oct. 3, 2022).Motors Powertrain, 166 F.3d 1209 (4th Cir. 1999) (per curiam) (quoting Crady v. Liberty Nat’l Bank & Trust Co., 993 F.2d 132, 136 (7th Cir. 1993)).
- Hunt v. Kelly Servs. Inc., No. 1:20-cv-01521 (S.D. Ind. Sept. 15, 2022). Co., 993 F.2d 132, 136 (7th Cir.1993)). "[N]ot everything that makes an employee unhappy is an actionable adverse action." Smart v. Ball State Univ., 89 F.3d 437, 441 (7th Cir. 1996).
- Pimentel v. Atrium Hosp. LP, No. 3:19-cv-01284 (D. Conn. Sept. 7, 2022).City Bd. of Educ., 202 F.3d 636, 640 (2d Cir. 2000) (quoting Crady v. Liberty Nat'l Bank and Trust Co., 993 F.2d 132, 136 (7th Cir. 1993)).
- Buksh v. Dr. William Sarchino DPM Foot & Ankle Surgeon, No. 2:21-cv-00190, 2022 WL 3444980 (D. Vt. Aug. 17, 2022).Co. of Indiana, 993 F.2d 132, 136 (7th Cir. 1993)).
- Thompson-Mooney v. Metro. Sec. Servs., Inc., No. 5:21-cv-00194 (E.D. Ky. Aug. 9, 2022).And generally, an adverse employment action “must be more disruptive than a mere inconvenience or an alteration of job responsibilities.” Kocsis v. Multi-Care Mgmt., Inc., 97 F.3d 876, 886 (6th Cir. 1996) (quoting Crady v. Liberty Nat’l Ba…
- Sean Kelly v. The Univ. of Vermont Med. Ctr., 2022 VT 26, 280 A.3d 366.publishedCo. of Ind., 993 F.2d 132, 136 (7th Cir. 1993).
- Orange v. United States Steel Corp., No. 2:19-cv-00452 (N.D. Ind. Mar. 30, 2022).“A materially adverse employment action is something ‘more destructive than a mere inconvenience or an alteration of job responsibilities.’” Rhodes v. Ill. Dept. of Transp., 359 F.3d 498, 504 (7th Cir. 2004) (quoting Crady v. Liberty Nat’l…
- Principe v. Vill. of Melrose Park, No. 1:20-cv-01545, 2022 WL 488937 (N.D. Ill. Feb. 17, 2022).Co. of Indiana, 993 F.2d 132, 136 (7th Cir. 1993)).
- Dunkley v. AFSCME, No. 3:18-cv-02189 (S.D. Ill. Oct. 5, 2021).An adverse employment action must be a “materially adverse change in the terms and conditions of employment . . . more disruptive than a mere inconvenience or an alteration of job responsibilities.” Rabinovitz v. Pena, 89 F.3d 482, 488 (7t…
- Sublett v. Masonic Homes of Kentucky, Inc., No. 3:19-cv-00708 (W.D. Ky. Sept. 30, 2021).Co. of Ind., 993 F.2d 132, 136 (7th Cir. 1993) (“[Plaintiff] would have maintained a management-level position at the same salary and benefits he was already receiving.
- Ray v. Salem Twp. Hosp., No. 3:19-cv-01048 (S.D. Ill. Sept. 28, 2021).An adverse employment action must be “more disruptive than a mere inconvenience or an alteration of job responsibilities.” See Nagle v. Vill. of Calumet Park, 554 F.3d 1106, 1120 (7th Cir. 2009)(citing Crady v. Liberty Nat'l Bank & Trust C…
- Hampton v. State of Utah Dep't of Corr., No. 1:18-cv-00079, 2021 WL 4307037 (D. Utah Sept. 22, 2021).The court “will not consider ‘a mere inconvenience or an alteration of job responsibilities’ to be an adverse employment action.” See Sanchez v. Denver Public Schools, 164 F.3d 527, 532 (10th Cir. 1998) (quoting Crady v. Liberty Nat’l Bank…
- Stanton v. Exelon Corp., No. 2020-2464 (D.D.C. Sept. 15, 2021).published (holding that materially adverse actions “might be indicated” by “a less distinguished title,” “significantly diminished material responsibilities, or other indices that might be unique to a particular situation.)
- Stieglitz v. City of Chicago, No. 1:19-cv-00076 (N.D. Ill. Sept. 3, 2021).(noting that “a decrease in wage or salary” can be materially adverse)
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- Bayless v. Ancilla Domini Coll., 781 F. Supp. 2d 740 (N.D. Ind. 2011).published
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- Porter v. Donahoe, 962 F. Supp. 2d 491 (E.D.N.Y. 2013).published
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- Perry v. Bath & Body Works, LLC, 993 F. Supp. 2d 883 (N.D. Ind. 2014).published
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At page 135 Determining materially adverse employment action under age discrimination law30 citing casesfinding no adverse action in transfer to another city where responsibilities were not diminished and salary and benefits remained the same
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At page 134 Determining employment termination through inaction13 citing casesRichards sent another letter on October 20, 1988, telling Crady that the loan officer position was being held open for him and asking him to provide a doctor’s…
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v.
LIBERTY NATIONAL BANK AND TRUST COMPANY OF INDIANA, Steve Richards, Branch Administrator, and Jack Ragland, Chief Executive Officer, Defendants-Appellees
Liberty National Bank and Trust Company of Indiana and Ernest Crady dispute the reasons for Crady’s discharge from Liberty. Crady sued Liberty pursuant to the Age Discrimination in Employment Act, 29 U.S.C. §§ 621-34 (“ADEA”). Liberty says Crady abandoned his job, forcing Liberty to discharge him. The district court granted Liberty’s motion for summary judgment. We affirm.
I.
We review a grant of summary judgment in the light most favorable to the nonmoving party; here, Ernest Crady. Liberty hired Crady in May 1987 when Crady was 53 years old. Crady asserts that he was hired as an assistant vice president and manager of Liberty’s Sellersburg branch, with the promise of a future salary increase and a title promotion. About a year later, Steve Richards, a bank executive at the appellee’s Charleston branch, told Crady that he would be transferred to the Charleston branch for a loan officer position managing collections. Liberty asserts that Crady’s transfer was the result of his difficulty in managing employees. The transfer did not involve a wage reduction, but the position was not as an assistant vice president. Crady felt it was a demotion and was unhappy about the change.
Before the transfer decision was final, Cra-dy was involved in a dispute with one of the employees on July 29, 1988. He became ill immediately following the altercation and left work to see his doctor. His doctor was not in, so Crady went home. Shortly after he arrived home, Crady and Richards spoke on the telephone, at which time Richards told Crady that the transfer to the Charleston branch would be effective on August 1. After the conversation, Crady went to the emergency room and was admitted to the hospital for two days.
On August 10,1988, Richards wrote Crady a one sentence note that said “Dear Ernie: Please have your physician drop us a small written notice concerning your illness for our files. Sincerely, Steve” (R. 30, Exh. B). On the bottom of the note, Crady authorized his physician to release a statement to Liberty. Subsequently, Liberty received the hospital discharge notice that reflected Crady’s diagnosis and condition. On September 19, 1988, Richards called Crady’s doctor and asked when Crady might be able to return to work. Crady’s doctor sent Richards a note that stated: “This specified in our talk this a.m., Ernest Crady feels able to return to his previous job upon request.” (R. 30, Exh. D). The doctor did not offer his opinion about whether Crady was medically incapable of performing the collections officer position.
[*134] Richards sent another letter on October 20, 1988, telling Crady that the loan officer position was being held open for him and asking him to provide a doctor’s certification that he could not perform the duties of that position at that time. Richards assured Cra-dy that the position would be held as long as possible, but warned him that it could not remain vacant indefinitely. Crady did not respond to the letter. On November 3,1988, Crady’s lawyer spoke to Liberty’s personnel director. After the conversation, Crady’s attorney told Crady of the possibility that Liberty would recommend a doctor to examine Crady for an independent opinion as to whether he was fit to return to work. No one ever contacted Crady about a possible doctor’s examination.
On November 7, 1988, Richards sent a third letter to Crady explaining that Liberty could not hold Crady’s job open indefinitely. He wrote that if Crady did not contact him by November 30, 1988, Richards could only assume that Crady had abandoned his employment with Liberty. This letter elicited a biting response. Crady’s attorney sent a letter warning Richards against writing Cra-dy directly. The attorney accused Richards of making an “end run” around him. The attorney did not, however, respond to Liberty’s request for medical documentation of Crady’s inability to return to work.
Despite the deadline, November 30 came and went without Crady informing Liberty about whether he intended to return to work. True to his word, Richards wrote Crady a letter telling him that because he had not responded, Liberty interpreted his inaction as abandonment of his employment and therefore his employment was officially terminated. Liberty’s attorney sent a similar letter to Crady’s attorney informing him of the termination. On December 1, Crady’s attorney wrote Liberty and asked that Crady be reinstated. He also informed Liberty that he believed Crady’s termination was retaliatory because the personnel director had allegedly been told that Crady was going to initiate an Equal Employment Opportunity Commission (“EEOC”) action. He enclosed two physicians’ statements concerning Cra-dy’s condition. One stated simply “It is not recommended that Ernest Crady be placed in a position of increased stress.” (R. 30, Exh. I). The other was a summary of Cra-dy’s complaints and medical history, but did not offer a diagnosis or employment recommendation.
Despite further correspondence, Crady was not reinstated. Crady ultimately filed a complaint with the EEOC. He alleged he was a victim of age discrimination and retaliatory discharge. The EEOC did not agree. Crady properly exhausted his administrative remedies and could (and did) sue Liberty for violations of the Age Discrimination in Employment Act. He did not argue his retaliation claim to this court.
II.
We review a district court’s grant of summary judgment de novo, considering the facts in the light most favorable to the non-moving party and determining whether a genuine issue of material fact exists. Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 106 S.Ct. 2505, 91 L.Ed.2d 202 (1986). In this case we must decide whether the undisputed facts show that Crady’s employment was terminated because of his age or because Liberty genuinely believed Crady had abandoned his employment.
The plaintiff who sues an employer for violations of the Age Discrimination in Employment Act, 29 U.S.C. §§ 621-34, bears the burden of proving age discrimination. One of the methods to accomplish this goal is to establish a prima facie case and apply the burden shifting method described in McDonnell Douglas Corp. v. Green, 411 U.S. 792, 93 S.Ct. 1817, 36 L.Ed.2d 668 (1973). See Hazen Paper Co. v. Biggins, — U.S. -, -, 113 S.Ct. 1701, 1708, 123 L.Ed.2d 338 (1993); Oxman v. WLS-TV, 846 F.2d 448 (7th Cir.1988). This is what Crady sought to do.
To do that successfully, Crady must show that 1) he was more than forty years old; 2) he performed his job satisfactorily; 3) despite his satisfactory performance he suffered a materially adverse employment action; and 4) Liberty treated others outside the protected class more favorably than Crady was treated. Konowitz v. Schnadig Corp., 965 F.2d 230, at 232. If Crady estab[*135] lished his prima facie ease, Liberty then bears the burden of producing a legitimate nondiscriminatory reason for the materially adverse employment action. Id.; Texas Dep’t of Community Affairs v. Burdine, 450 U.S. 248, 253-54, 101 S.Ct. 1089, 1093-94, 67 L.Ed.2d 207 (1981). If Liberty produces a legitimate reason, Crady bears the burden of persuading the court that the reason was merely a pretext for the employment action. Konowitz, 965 F.2d at 233.
Crady’s climb up the rungs of the prima facie ladder is a short one. He clears the first rung that put him in a protected class because he is more than forty years old. Whether he clears the second rung is an open question. We do not have to decide that question for purposes of this opinion because Crady stumbles on rung three. The district court held that Crady failed to establish that the transfer was a materially adverse employment action. The district court held further that even if Crady had established that the transfer was materially adverse and hence established a prima facie case, he could not counter Liberty’s legitimate nondiscriminatory reason for the employment action — that Crady had abandoned his employment. We agree with the district court.
This case is similar to Spring v. Sheboygan Area School District, 865 F.2d 883 (7th Cir.1989). There, the Sheboygan, Wisconsin school district was reorganized and as a result of that reorganization, Spring, an elementary school principal who was more than 65 years old, was offered either the opportunity to transfer to another school or retirement. The job at the new school was a joint-principal position shared with another individual. Spring resigned and sued the school district for ADEA violations and constructive discharge. She alleged that the position she would have as a result of the transfer was a “public humiliation.” We found that “public humiliation” was not sufficient to establish age discrimination and constructive discharge because “public perceptions were not a term or condition of Spring’s employment.” Spring, 865 F.2d at 886. [1]
We considered other factors to determine whether Spring established a prima facie case of discrimination. We looked at the work assignments by other principals within the school district and compared the special education programs, the number of students, the size of the staff, and the administrative workload at both schools. Because Spring never worked at the transfer position, she could not support her claims of a dramatically increased administrative workload at the transfer school. We paid heed to the district court’s conclusion that the only negative accompanying Spring’s job transfer was that she would be required to travel a greater distance to work, although she would be reimbursed for that travel. We noted that Spring stated, apparently under oath, “I don’t think [the transfer position] was a lesser job” and that she received a merit pay increase and two-year contract with the transfer. Id. We held that the transfer was not a materially adverse employment action and that Spring did not establish a prima facie case of age discrimination. Id.
Like Spring, Crady did not show that his transfer from the Sellersburg branch manager position to a collections officer posi[*136] tion in Charleston was a materially adverse employment action. As we indicated in Spring, a materially adverse change in the terms and conditions of employment must be more disruptive than a mere inconvenience or an alteration of job responsibilities. A materially adverse change might be indicated by a termination of employment, a demotion evidenced by a decrease in wage or salary, a less distinguished title, a material loss of benefits, significantly diminished material responsibilities, or other indices that might be unique to a particular situation. See Brown v. M & M/Mars, 883 F.2d 505 (7th Cir.1989) (employee terminated as a result of age discrimination); see also Weihaupt v. American Medical Ass’n, 874 F.2d 419, 427 (7th Cir.1989) (plaintiff was displaced as departmental director); Spring, 865 F.2d at 886. Crady would have maintained a management-level position at the same salary and benefits he was already receiving. Although his responsibilities changed, he does not show that they were less significant than the responsibilities he previously enjoyed in Sellersburg. Assuming that Crady was an assistant vice president in Sellersburg and that the collections officer position did not carry the AVP designation, this alone is not enough to constitute a materially adverse employment action.
Finally, even if we assume as did the district court that Crady established a prima facie ease of discrimination, we agree that he failed to establish that Liberty’s reasons for terminating him were pretextual. Crady failed to provide medical documentation prior to his termination that established that he was unable to return to work. This lack of information was coupled with Crady’s failure to respond to Liberty’s request that he state his employment intentions before November 30. Under these circumstances, we hold that Crady’s discharge for abandonment of his employment was not a pretext for age discrimination.
III.
The district court judgment is Affiímed.
. A district court in Kentucky stated that "[t]he clear trend of authority is to require that a transfer with no change in wages or benefits amount to a 'constructive discharge' to be actionable as an 'adverse employment action.’ ” Darnell v. Campbell County Fiscal Court, 731 F.Supp. 1309, 1313 (E.D.Ky.1990), aff'd, 924 F.2d 1057 (table) (6th Cir.1991). When affirming, the Sixth Circuit held that "an employee's rejection of a lateral transfer precludes her from arguing that her termination was an 'adverse employment decision’ for purposes of establishing a prima facie case” citing the Seventh Circuit opinion in Greenberg v. Kmetko, 840 F.2d 467, 475 (7th Cir.1988) (en banc), and Spring v. Sheboygan Area School District, 865 F.2d 883 (7th Cir.1989). The Sixth Circuit decision may not be cited as precedent under local Sixth Circuit rules. The application of the constructive discharge standard to lateral transfers at issue in ADEA claims was noted by a district court in the Seventh Circuit. Addams v. City of Chicago, 1992 WL 348848, 1992 U.S.Dist. Lexis 17542, No. 92 C 2893 (N.D.IL. Nov. 12, 1992). Crady, however, does not argue that the conditions surrounding his new job assignment were so untenable that they rendered his continued employment an impossibility, the proof required to establish constructive discharge. Henn v. National Geographic Society, 819 F.2d 824, 829 (7th Cir.1987). Therefore, we do not need to consider application of the constructive discharge standard to the instant case.