News & Analysis as of

Appeals Title VII

Parker Poe Adams & Bernstein LLP

Sixth Circuit Takes Restricted View of Employer Liability for Third-Party Harassment

For years, both the Equal Employment Opportunity Commission and multiple federal appellate circuits have agreed on the legal standard for proving liability for sexual or other harassment by a third party such as a vendor or...more

Phelps Dunbar

Sixth Circuit Redefines Employer Liability for Client-Based Harassment

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In an explicit departure from EEOC guidance and other federal court caselaw, the United States Court of Appeals for the Sixth Circuit recently held that an employer can only be liable for a client/customer’s harassment of its...more

FordHarrison

Sixth Circuit Requires Proof of Intent for Employers to be Liable for Harassment by a Nonemployee

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On August 8, 2025, in Bivens v. Zep, Inc., the United States Court of Appeals for the Sixth Circuit held that employer liability for nonemployee harassment requires proof of the employer’s intent, a departure from the...more

Kerr Russell

Supreme Court and Sixth Circuit Case Law Updates

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From the U.S. Supreme Court to the Sixth Circuit Court of Appeals, courts have issued rulings that clarify — and in some cases, reshape — key aspects of labor and employment law....more

Poyner Spruill LLP

Why Comparator Analysis Matters: A Key Fourth Circuit Ruling

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Title VII of the Civil Rights Act of 1964 generally prohibits covered employers from taking adverse actions against employees on the basis of race, sex, and other protected categories. Employee discipline is often the subject...more

Proskauer - California Employment Law

Supreme Court Invalidates Heightened Evidentiary Standard For Majority-Group Plaintiffs

Ames v. Ohio Dep’t of Youth Servs., 605 U.S. ___, 145 S. Ct. 1540 (2025) - Marlean Ames, a heterosexual woman, alleged under Title VII that she had been denied a management promotion and demoted based on her sexual...more

Perkins Coie

June Tip of the Month: Supreme Court Decision Levels the Playing Field for “Reverse Discrimination” Claims

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On June 5, 2025, the U.S. Supreme Court issued a unanimous decision in Ames v. Ohio Department of Youth Services, holding that members of a majority group are not required to meet a heightened evidentiary standard to prevail...more

Cranfill Sumner LLP

Supreme Court Unanimously Rejects “Background Circumstances” Requirement for “Reverse Discrimination” Claims

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The U.S. Supreme Court unanimously held on June 5, 2025, that majority group plaintiffs are not required to meet a heightened evidentiary standard of showing “background circumstances” to establish a prima facie case of...more

Mandelbaum Barrett PC

The U.S. Supreme Court Makes It Easier for Employees in the Majority to Prove Reverse Discrimination Under Title VII

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The United States Supreme Court on June 5, 2025, in a rare unanimous decision, overturned a decision from the Sixth Circuit Court of Appeals that required a plaintiff, a heterosexual, to have evidence as part of her proofs to...more

Kelley Drye & Warren LLP

Unanimous Supreme Court Decision Potentially Prompts Future Litigation

The Supreme Court’s June 5, 2025 decision to revive a heterosexual woman’s discrimination suit on the basis of sexual orientation against her employer could open a floodgate of future litigation. In a unanimous ruling...more

Warner Norcross + Judd

Supreme Court Rejects Heightened Evidentiary Standard for Majority-Group Plaintiffs in Title VII Discrimination Claims

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On June 5, the U.S. Supreme Court unanimously held in Ames v. Ohio Dept. of Youth Services that courts cannot apply a heightened evidentiary standard to majority-group plaintiffs when deciding discrimination claims. The...more

Bricker Graydon LLP

Supreme Court Rejects “Background Circumstances” Requirement for Title VII Discrimination Claims in Ames v. Ohio Department of...

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In a unanimous decision issued on June 5, 2025, the United States Supreme Court held the “background circumstances” requirement imposed by some lower courts in what are often referred to as “reverse discrimination” claims is...more

McGlinchey Stafford

SCOTUS Ames Decision: Everyone’s in a “Protected Class”

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In employment law, we traditionally think of discrimination as applying to minority groups: African Americans, women, homosexuals, or other legally protected groups. In analyzing discrimination claims, one of the first...more

Harris Beach Murtha PLLC

SCOTUS Rejects Heightened Standard for Title VII Majority Group

In Ames v. Ohio Dep’t of Youth Servs., No. 23-1039, 2025 WL 1583264, (U.S. June 5, 2025), the U.S. Supreme Court unanimously held that majority group plaintiffs (in this instance, a heterosexual plaintiff) do not need to meet...more

Steptoe & Johnson PLLC

Trump Executive Order Takes Aim at Disparate-Impact Liability

Steptoe & Johnson PLLC on

On April 23, President Donald Trump issued Executive Order 14281 (EO), “Restoring Equality of Opportunity and Meritocracy,” 90 FR 17537, 2025 WL 1207532. The EO takes aim at disparate-impact liability, which the EO says...more

Pierce Atwood LLP

Supreme Court Clarifies Title VII Evidentiary Standards in “Reverse Discrimination” Cases, Removing Heightened Standard

Pierce Atwood LLP on

In Ames v. Ohio Dept. of Youth Servs., the U.S. Supreme Court recently settled a circuit split and held that the Sixth Circuit’s “background circumstances” rule, which was applied only to plaintiffs from majority...more

Parker Poe Adams & Bernstein LLP

Supreme Court Rejects Elevated Standard for Proving Reverse Discrimination Claims

The U.S. Supreme Court unanimously rejected use of a special legal test for plaintiffs to prove illegal bias in reverse discrimination cases. ...more

Patterson Belknap Webb & Tyler LLP

Supreme Court Rejects Heightened Evidentiary Burden For “Reverse Discrimination” Title VII Plaintiffs

On June 5, 2025, in a unanimous ruling authored by Justice Ketanji Brown Jackson, the U.S. Supreme Court revived the employment discrimination claims of an Ohio woman who contends that she was the victim of “reverse...more

Troutman Pepper Locke

Supreme Court Strikes Down Sixth Circuit Rule Heightening Discrimination Standard for Members of Majority Groups

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A recent Supreme Court decision clarified that discrimination claims brought by members of majority groups in so-called “reverse discrimination” cases cannot be subject to a heightened evidentiary burden. In Ames v. Ohio...more

Harris Beach Murtha PLLC

How Courts are Applying the “Some Harm” Standard Since Muldrow

More than a year has passed since the U.S. Supreme Court unanimously held in its April 2024 decision in Muldrow v. City of St. Louis, Missouri, 601 U.S. 346, 144 S. Ct. 967, 218 L. Ed. 2d 322 (2024) that employees need only...more

Brooks Pierce

High Court Unanimously Rejects the Imposition of Special Requirements for “Majority Group” Discrimination Claims

Brooks Pierce on

On Thursday, June 5, 2025, the Supreme Court unanimously rejected the notion that Title VII of the Civil Rights Act of 1964 (“Title VII”) imposes special requirements on a “majority-group” plaintiff trying to make an initial...more

Arnall Golden Gregory LLP

Supreme Court Eliminates Heightened Standard for “Reverse Discrimination” Claims

On June 5, 2025, the Supreme Court of the United States unanimously ruled in Ames v. Ohio Department of Youth Services that plaintiffs alleging employment discrimination under Title VII of the Civil Rights Act of 1964 are not...more

Berkshire

Supreme Court Rejects Higher Standards for Majority Plaintiffs in Title VII Disparate Treatment Cases

Berkshire on

The Supreme Court has voted unanimously to end a Circuit Court split regarding whether members of a “majority group” have additional evidentiary burdens when bringing a case under Title VII of the Civil Rights Act for...more

Constangy, Brooks, Smith & Prophete, LLP

Justice Thomas continues to ask litigants to challenge McDonnell Douglas standard

In March, the U.S. Supreme Court majority declined to review a decision affirming summary judgment for an employer in a discrimination case. Justice Clarence Thomas, joined by Justice Neil Gorsuch, dissented, noting that he...more

Littler

Littler Lightbulb – May Employment Appellate Roundup

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Fourth Circuit Dismisses White Employee’s Race, Gender, and Retaliation Claims - Barnhill v. Pamela Bondi, __ F.4th __ (4th Cir. May 15, 2025) involved claims by a white Department of Justice Drug Enforcement Administration...more

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