The U.S. Supreme Court’s ruling in Muldrow v. City of St. Louis, Mo. is a “win” for plaintiffs who pursue claims under Title VII. Employees who are discriminated against should learn how the ruling makes it easier to prove discrimination.

What is Title VII?

Title VII relates to the Civil Rights Act of 1964 (Title VII), which provides employees with protection against discrimination based on:

Color
Race
Religion
Sex
National origin

Employers cannot retaliate or take negative action against an employee because they file a discrimination claim or were witnesses in an investigation or lawsuit relating to discrimination against the employer.

Discrimination cannot be made at any point or aspect of employment, such as during hiring, firing, layoff, testing, training and so on.

Understanding the Muldrow v. City of St. Louis, Mo. Case

Muldrow v. City of St. Louis is a case brought by Sargeant Jatonya Clayborn Muldrow against the St. Louis Police Department. Muldrow was transferred out of her position after nearly 10 years and claimed the transfer was due to her sex.

She failed to show that she experienced a “materially significant disadvantage” due to her transfer. So, the case was brought to the Supreme Court.

Prior to the ruling, the Court followed a “heightened harm” standard when deciding Title VII discrimination claims. Her case ended with:

Summary judgment for the City by the district court
Eight Circuit affirmed

What the ruling offers is a victory for workers because employees no longer need to prove that the discrimination led to a “significant disadvantage.”

Muldrow’s case is now headed to reconsideration under the new standard.

What the Decision on Muldrow v. City of St. Louis, Mo. Means for Employees

The Muldrow v. City of St. Louis ruling is a win for workers and bars employers from discriminating in decisions such as lateral transfers. Many workers have, in the past, had valid discrimination claims dismissed all too easily by courts due to the “materially” or “significantly” adverse standard.

Previously, employees had to show that there was significant harm to their employment, such as important differences in their:

Benefits
Salaries
Work hours
Job titles and/or duties
Prospects for promotions

Under the new ruling, employer actions regarding job transfers no longer need to produce “significant” harm in order to be actionable under Title VII. Rather, employees only need to show that some harm resulted from the decision.

The ruling strengthens protections from discrimination in the workplace and effectively lowers the plaintiff’s burden of proof to sustain a claim under Title VII.

It’s important to note, however, that the Court’s decision focuses on discriminatory job transfers. It remains to be seen whether the same reasoning will apply to other allegedly harmful employer actions under Title VII.

However, the Court’s analysis may well apply to employment opportunities such as mentoring, assignments or training.

Annually, 81,055 new charges of discrimination are filed, according to the U.S. Equal Employment Opportunity Commission (the EEOC). The ruling may impact many of these cases.

How Do I File an Employment Discrimination Claim?

If you’ve been discriminated against in the workplace, you may be entitled to damages. The experienced and compassionate attorneys at Ricotta & Marks, P.C. can help you understand your options and advocate on your behalf.

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