Eighth Circuit: David Bonenberger v. St. Louis Metro. Police Dept.

Title VII, S1983 Conspiracy

Denial of sought-for promotion is an adverse employment action where the change would have been marked by a material change in working conditions.

Conspiracy verdict upheld where the jury might have inferred that knowledge of the discrimination demonstrated active complicity in the discrimination.

http://media.ca8.uscourts.gov/opndir/16/01/143696P.pdf