See City of Holyoke, 35 MLC 153, 156 (2009). Direct evidence of discriminatory animus is rarely found in discrimination actions, however. See Trustees of Health and Hospitals of the City of Boston, Inc. v. Massachusetts Commn. Against Discrimination, 65 Mass. App. Ct. 329, 336 n. 8 (2005).

City of Holyoke, 35 MLC 153, 156 Town of Carver, 35 MLC 29, 47 (2008); Quincy School Committee, 27 MLC 83, 92 (2000); Town of Clinton, 12 MLC 1361, 1365 (1985). McKenzies concerted, protected activity The filing and processing of grievances constitutes concerted, protected activity protected (2008); by Section citing Quincy Education, 32 MLC 2 of the Law. School See Committee, Newton School Committee, 27 at 91.

City of Holyoke, 35 MLC 153, 156 (2009). Once the charging party establishes a prima facie case, if the employer provides lawful reasons for the alleged discriminatory conduct, the charging party must then prove that but for the protected activity, the employer would not have taken the adverse action. Trustees of Forbes Library, 384 Mass. 559, 565-566 (1981).

City of Holyoke, 35 MLC 153, 156 (2009). Once the charging party establishes a prima facie case, if the employer provides lawful reasons for the alleged discriminatory conduct, the charging party must then prove that but for the protected activity, the employer would not have taken the adverse action. Trustees of Forbes Library, 384 Mass. 559, 565-566 (1987).

City of Holyoke, 35 MLC 153, 156, MUP-05-4503 (January 9, 2009) (citing Town of Dracut, 25 MLC 131, 133, MUP-1397 (February 17, 1999)). Many management decisions, though possibly inconvenient or even undesirable, do not constitute adverse employment actions unless the charging party is materially disadvantaged in some way. See City of Boston, 35 MLC 289, 291, MUP-04-4077 (May 20, 2009) (citing Maccormack v.

City of Holyoke, 35 MLC 153, 156, MUP-05-4503 (January 9, _ 2009). Once the charging party establishes a prima facie case, if the employer provides lawful reasons for the alleged discriminatory conduct, the charging party must then prove that but for the protected activity, the employer would not have taken the adverse action. Trustees of Forbes Library, 384 Mass. 559, 565-566 (1981).

City of Holyoke, 35 MLC 153, 156, MUP-04-4503 (Jan. 9, 2009). 1. No Employer Knowledge While | find that Sullivan was engaged in concerted, protected activity when he filed his DESE petition on June 21, 2015, there is no evidence that the Committee knew about that activity on June 23, 2015.

City of Holyoke, 35 MLC 153, 156, MUP-04-4503 (January 9, 2009). Here, the Union alleges that McKinnon, Conille, and Dominique engaged in protected, concerted activity by participating as officers of the Union, and when McKinnon and Conille participated in past Department proceedings. There is no dispute that this is protected, concerted activity and that DDS knew of this activity.

Matter of City of Holyoke and 2 International Brotherhood of Police Officers, Local 388, Mass L.R.C. Case No. MUP-2734, *2 (2002).

City of Holyoke, 35 MLC 153, 156, MUP-04-4503 (Jan. 9, 2009); Town of Carver, 35 MLC 29, 47, MUP-03-3094 (June 30, 2008); Quincy School Committee, 27 MLC 83, 92, MUP-1986 (Dec. 29, 2000); Town of Clinton, 12 MLC 1361, 1365, MUP5659 (Nov. 9, 1985). 1.

City of Holyoke, 35 MLC 156, MUP-05-4503 (January 9, 2009). Once the charging party establishes 153, a prima facie case, if the employer provides lawful reasons for the alleged discriminatory conduct, the charging party must then prove that but for the protected activity, the employer would not have taken the adverse action. Trustees of Forbes Library, 384 Mass. 559, 565-566 (1981).