Garces, 9 OCB2d 23 (BCB 2016)
Petitioner argued that NYCHA violated NYCCBL § 12-306(a)(1) and (3) by removing job duties and transferring him in retaliation for filing an out-of-title grievance. NYCHA argued that Petitioner did not suffer an adverse employment action and that it had legitimate business reasons for the transfer. The Board found that the removal of the job duties was not an adverse employment action. The Board further found that Petitioner failed to establish a prima facie case of retaliation regarding his transfer. Accordingly, the Board dismissed the improper practice petition.