(908)402-4770On April 17, 2024, the U.S. Supreme Court issued an important decision in Muldrow v. City of St. Louis, Missouri. The Court ruled that under Title VII of the Civil Rights Act of 1964, employees who experience discriminatory job transfers don’t need to show that their harm was significant—only that there was some harm to their job conditions.
The plaintiff, Jatonya Muldrow, was a sergeant in the St. Louis Police Department. She claimed her supervisor transferred her from her Intelligence Division position to a patrol job because she wanted to hire a male to replace her. She also alleged that she later applied for a transfer, but that request was denied. Although her rank and pay stayed the same, her new position had different responsibilities, fewer perks, and a less favorable schedule.
The lower courts ruled against Muldrow, saying she had to prove the initial transfer and the subsequent denial of a transfer request caused her a “materially significant disadvantage.” The Court of Appeals for the 8th Circuit held that since her title, salary, and benefits didn’t change, and the working conditions only changed slightly, her case didn’t meet that standard.
However, the Supreme Court disagreed. In a unanimous decision authored by Justice Kagan, the Supreme Court held that to win a Title VII case, an employee only needs to show that the transfer caused some negative change in job terms or conditions because of discrimination. In other words, the employee did not have to meet a higher standard of significant or material disadvantage.
Justice Kagan clarified that while employees still need evidence of harm, the bar for what counts as harm is now lower. This empowering ruling means more employees might successfully challenge job transfers they believe are discriminatory, offering a glimmer of hope for those who have felt powerless in such situations.
If you feel a job transfer or some other action by your employer, which has negatively affected your work conditions, was based on discrimination, the Supreme Court’s latest ruling could help your case. The experienced wrongful termination and civil rights attorneys at Schiller, Pittenger & Galvin, P.C., are here to support you. Call us at our Scotch Plains office at 908 402 4770 or email us here.