This is a great question but employers can come up with a variety of methods of retaliating against an employee short of discharging that employee. The U.S. Supreme Court in Burlington Northern v. White (2006; see LegalSpeak, p. 242) determined that employers retaliate against employees under Title VII if the employer engages in conduct that is materially adverse to an employee or engages in conduct that would deter a reasonable employee from complaining about retaliatory conduct.