First Circuit: Carlson v. University of New England

Where an employer claims that an allegedly retaliatory transfer was voluntary, misrepresentations made by the employer to the employee must have a non-retaliatory justification in order to prevail at summary judgment.

In order to present an issue for trial, a claim that an annual raise was artificially low must be supported by a benchmark of prior years salary decisions.

http://media.ca1.uscourts.gov/pdf.opinions/17-1792P-01A.pdf