The U.S. 6th Circuit Court of Appeals recently grappled with the question of what constitutes actionable harm to an employee in an employment discrimination case. Let’s look at what the court decided. Facts Mark Laster, an African-American male, worked for the city of Kalamazoo, Michigan. In June 2010, President Barack Obama was a guest speaker at a Kalamazoo high school. Laster acquired several tickets to the event.