Negative Job References

Normally, Negative Job References in Federal Employment would be looked at as a claim pursuant under Title VII, but can they be looked at alternatively as an additional "injury" which is a result of retaliation caused by an initial injury that stemmed from a violation as to the exception in 28 USC 2680(h), which involved claims against federal employees who fit the criteria of " law enforcement proviso"? If so, can Negative Job References be considered a tort claim which is part and parcel of a possible "continuing tort claim" which could receive damages based upon tort law, rather than damages pertaining to employment law? (See U.S. Court of Appeals for the District of Columbia in Jacobs v. Vrobel, No. 12-5107)