In City of El Paso v. Parsons, 353 S.W.3d 215 (Tex. App.--El Paso 2011, no pet.) a firefighter was transferred from his position at the training academy after he reported the fire chief's submission of false reports concerning employee continuing-education requirements.
The firefighter lost his responsibility as training chief, and other firefighters were removed from his supervision. Id. at 221.
He retained his job title, however, and received pay increases. Id.
The court of appeals held the evidence legally sufficient for a jury to conclude the firefighter's transfer constituted an adverse personnel action. Id. at 228.