This was never a factor in either of our cases. I suspect that's because when a manager knows he is cheating an employee, these issues never enter his mind.
Can you imagine the Infinity or UAB managers making this statement: "We know we are firing you for blatantly unlawful reasons, but hey, we'll give you good references in the future. That should make things about even, don't you think?"
What kind of final grades do Infinity and UAB receive? They both fail--utterly, totally, and miserably.
But they still have a chance to improve their grades. When it comes to the rule that says "drag the process out, even when you know you've screwed the employee," we feel quite certain that they will score quite high.