Given the task definition and input, reply with output. In this task, you will be shown a prompt from a judicial decision and multiple holding statements derived from citations following text in a legal decision. Holdings represent the governing legal rule when the law is applied to a particular set of facts. There are five answer choices for each citing text. The correct answer is the holding statement that corresponds to the citing text. You should write an incorrect option. Even though there exist multiple wrong answers, we only need a single wrong answer. There is a <HOLDING> token in the position of the citing text prompt where the holding statement was extracted.

that restricts the type of retaliatory act that might be visited on an employee who seeks to invoke her rights by filing a complaint.") Further, it appears that if retaliation does take the form of an employment action, such action need not be as severe as that required to state a discrimination claim. Herrnreiter, 315 F.3d at 746. In Hermreiter, the Seventh Circuit criticized a number of decisions that stated or assumed that in a retaliation context, an employment action must be as severe as in a discrimination context. The court did not resolve the question of what conduct is necessary to be actionable in a retaliation context, but cited or discussed a number of cases which are instructive on the issue. See, e.g., Passer v. Am. Chem. Soc'y, 935 F.2d 322, 331 (D.C.Cir.1991) (<HOLDING>); Berry v. Stevinson Chevrolet, 74 F.3d 980,
Holding statements: (A) holding that cancellation of a symposium in employees honor was a sufficient act of retaliation (B) recognizing first amendment retaliation right (C) holding that cancellation of benefit to honor plaintiff in retaliation for filing an age discrimination complaint constitutes adverse employment action because of public humiliation involved (D) holding plaintiff did not exhaust his retaliation claim where his eeoc charge made no mention of retaliation (E) holding that the fact that employer had knowledge of the employees protected activity was not sufficient to establish a prima facie case of retaliation where the timing of the discharge was not proximate to the protected activity
recognizing first amendment retaliation right