An employee challenging a job transfer under Title VII of the Civil Rights Act must show the transfer brought about some harm with respect to an identifiable term or condition of employment, but that harm need not be significant, the U.S. Supreme Court held in Muldrow v. City of St. Louis, Mo., No. 22-193 (Apr. 17, 2024).
Muldrow v City of St. Louis
Supreme Court Clarifies Standard Employees Must Show for Title VII Discrimination Claims
In Muldrow v. City of St. Louis, the U.S. Supreme Court purports to clarify the standard of harm employees must show when alleging an involuntary transfer was discriminatory
US Supreme Court Holds Lateral Job Transfers Can Be Discriminatory Under Title VII
By: US Supreme Court Holds Lateral Job Transfers Can Be Discriminatory Under Title VII
By: US Supreme Court Holds Lateral Job Transfers Can Be Discriminatory Under Title VII
On April 17, 2024, the United States Supreme Court delivered a win to employees holding that a lateral job transfer can be discriminatory under
High Court Lowers the Bar on Title VII Claims: “Significant” Harm No Longer Required
On April 17, 2024, the Supreme Court decided that employees do not need to suffer “significant” harm to state a claim of discrimination under Title VII. In so ruling, the Court rejected a level of proof as to harm that many lower courts had long required Title VII plaintiffs establish
Supreme Court Rules Employees Need Not Show Transfer Caused ‘Significant’ Harm For Title VII Claims
On April 17, 2024, the Supreme Court of the United States held that an employee challenging a job transfer in an unlawful employment discrimination claim under Title VII of the Civil Rights Act of 1964 must show that the transfer caused some identifiable harm, but the harm does not need
Muldrow v. City of St. Louis: Will SCOTUS Lighten the Prima Facie Burden For Title VII Plaintiffs?
Supreme Court Appears Ready to Hold Title VII Does Not Require a Materially Adverse Employment Action – Significant Implications for Employers on the Horizon
On December 6, 2023, the Supreme Court of the United States (SCOTUS) heard arguments in Muldrow v. City of St. Louis, Missouri—a potentially pivotal case concerning whether Title VII requires plaintiffs to establish a “materially adverse” employment action, “objective tangible harm,” or an “ultimate employment decision” to state a
U.S. Supreme Court Appears to Side With Employee Alleging Discriminatory Transfer in Oral Argument
Even as the U.S. Supreme Court heard oral argument in Muldrow v. City of St. Louis, Mo., No. 22-193, on Dec. 6, 2023, on the narrow issue of whether Title VII of the Civil Rights Act of 1964 prohibits job transfers that do not cause a “significant disadvantage” to workers, it hinted at future battles over the scope of workplace discrimination. The justices appeared sympathetic to workers and expressed concerns about limiting the scope of Title VII.