In Phillips v. Bowen (278 F3d 103 [2d Cir 2002]) the United States Court of Appeals for the Second Circuit stated that: "adverse employment actions include discharge, refusal to hire, refusal to promote, demotion, reduction in pay, and reprimand." The court then stated that "lesser actions by an employer may meet the adversity threshold," although the court recognized that "it had not explicitly defined what quantum of lesser actions constitutes an adverse employment action." (Id.) The court further recognized that while case precedent "allows a combination of seemingly minor incidents to form the basis of a constitutional retaliation claim once they reach critical mass," there was a "need for plaintiffs to demonstrate a certain severity of harm so that minor incidents or changes in working conditions would not form the basis for a constitutional claim." (Id.) The court ultimately held that: "in order to prove a claim of First Amendment retaliation in a situation other than the classic examples of discharge, refusal to hire, refusal to promote, demotion, reduction in pay, and reprimand, plaintiff must show that (1) using an objective standard; (2) the total circumstances of her working environment changed to become unreasonably inferior and adverse when compared to a typical or normal, not ideal or model, workplace." (Id.) The court went on to clarify that "incidents that are relatively minor and infrequent will not meet the standard, but otherwise minor incidents that occur often and over a longer period of time may be actionable if they attain the critical mass of unreasonable inferiority." (Id.)