News & Analysis as of

Title VII Muldrow v City of St Louis

Title VII of the Civil Rights Act is a United States federal law enacted in 1964 and aimed at preventing discrimination in the workplace on the basis of race, color, sex, national origin, and religion. Title VII... more +
Title VII of the Civil Rights Act is a United States federal law enacted in 1964 and aimed at preventing discrimination in the workplace on the basis of race, color, sex, national origin, and religion. Title VII has been subsequently extended to discrimination on the basis of pregnancy and sexual stereotypes and to prohibit sexual harassment. Title VII applies to all employers with fifteen or more employees including private employers, state and local governments, and educational institutions.  less -
Steptoe & Johnson PLLC

Evaluating the Employee Evaluation Process: There’s No Time Like the Present!

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Now is a good time to re-evaluate your company’s employee evaluation process in light of the prevalence of remote work and a U.S. Supreme Court decision lowering the requirements for employees to succeed on certain...more

Parker Poe Adams & Bernstein LLP

Muldrow Decision Should Result in Supervisor Training on Legal Risks From Workplace Changes

Last year, the U.S. Supreme Court issued a decision in Muldrow v. City of St. Louis that has resulted in profound changes to when employees can claim discrimination relating to job decisions that do not appear to have much...more

Rumberger | Kirk

U.S. Supreme Court Denies Heightened Standard in “Reverse Discrimination” Claims

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A recent Supreme Court decision is reshaping how employers must think about workplace discrimination—confirming that all employees, majority or minority, are held to the same legal standard under Title VII. This shift could...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

Mintz - Employment Viewpoints

“Reverse Discrimination” Cases Subject to Same Evidentiary Standard Says Supreme Court

Can members of a majority group be subject to a heightened pleading standard for their Title VII discrimination claims? The United States Supreme Court answered this question with a unanimous “no” in Ames v. Ohio Department...more

Jackson Lewis P.C.

U.S. Supreme Court Reverses ‘Reverse’ Employment Discrimination Pleading Standard

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On June 5, 2025, the U.S. Supreme Court invalidated the “background circumstances” rule in “reverse” employment discrimination claims brought under Title VII of the Civil Rights Act in a unanimous decision overturning...more

Keating Muething & Klekamp PLL

PIP This: The Expansion of Actionable Adverse Employment Decisions in the Wake of Muldrow v. City of St. Louis

Over the course of the last year, employers have faced increased claims from employees testing what constitutes an actionable adverse action under the anti-discrimination provision of Title VII of the Civil Rights Act of 1964...more

Amundsen Davis LLC

Lowering the Legal Standard for Establishing Workplace Harassment Claims

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In the wake the U.S. Supreme Court’s April 2024 decision in Muldrow v. City of St. Louis, some federal courts feel compelled or justified applying the same rationale to lower the standard to prove up workplace harassment...more

Rumberger | Kirk

From Hamilton To Muldrow: Preparing HR For Title VII Claims Beyond The Firing Table

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“The Hamilton decision highlights the need for employers to stay up to date on legal developments. In this one decision, the Fifth Circuit opened the door for claims that just one day earlier were not actionable. Reviewing...more

Mintz - Employment Viewpoints

SCOTUS Takes Up Reverse Discrimination Framework Under Title VII

The U.S. Supreme Court recently granted cert in a hotly contested case addressing the standards of proof applicable to reverse discrimination claims under Title VII. The case comes on the heels of the court’s decision last...more

Davis Wright Tremaine LLP

SCOTUS Takes Up Another Case With DEI Implications

Last week, the Supreme Court accepted review of Ames v. Ohio Department of Youth Services. The court will address a circuit split regarding the standard courts apply in discrimination claims brought by majority group...more

FordHarrison

How Courts Have Analyzed Discrimination Claims after the U.S. Supreme Court's Decision in Muldrow v. City of St. Louis, Missouri:...

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Real World Impact: In April, the Supreme Court issued a decision in Muldrow v. City of St. Louis, Missouri, lowering the standard that federal courts had applied for decades on discriminatory transfer claims under Title VII...more

Lathrop GPM

Title VII & Lateral Transfers - Treacherous Territory after United States Supreme Court Ruling

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The United States Supreme Court recently settled a circuit split concerning when an involuntary lateral transfer may violate Title VII of the Civil Rights Act of 1964. The Court’s opinion in Muldrow v. City of St. Louis...more

Foley & Lardner LLP

Shifting Views on Paid Administrative Leave

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Employers often place employees on paid administrative leave while they investigate accusations of employee misconduct or make decisions regarding the employees’ employment. Traditionally, most federal courts agreed that this...more

PilieroMazza PLLC

Supreme Court Opens Door to Broader Spectrum of Employment Discrimination Cases

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In April 2024, the U.S. Supreme Court held that transferring an employee to a new position with the same rank and pay may constitute an adverse action under Title VII. The recent decision in Muldrow v. City of St. Louis,...more

Jackson Lewis P.C.

EEOC Commissioner Andrea Lucas Discusses Workplace DEI

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Jackson Lewis Principal and Board Member Tanya Bovée interviewed U.S. Equal Employment Opportunity Commission (EEOC) Commissioner Andrea Lucas at Jackson Lewis’ Workplace Horizons conference in Las Vegas on April 17, 2024. ...more

Fisher Phillips

SCOTUS 2023/24 Lookback and Preview: 8 Key Rulings that Impact the Workplace and 4 New Cases for Employers to Track Next Term

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The Supreme Court issued several momentous decisions last term that will have a lasting impact on employer practices. The Justices continued to shape the workplace law landscape by ruling on an array of issues involving...more

Jackson Lewis P.C.

EEOC VC Samuels’ Keynote at Workplace Horizons Addresses PWFA, AI, Muldrow & More

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Jocelyn Samuels was designated by President Joe Biden as Vice Chair of EEOC on January 20, 2021. She joined the EEOC as a Commissioner on October 14, 2020, and on July 14, 2021, was confirmed for a second term ending in 2026....more

Skadden, Arps, Slate, Meagher & Flom LLP

Supreme Court Lowers the Bar for Title VII Employment Claims

Title VII of the Civil Rights Act requires employees alleging employment discrimination to show they suffered an adverse employment action as a result of their membership in a protected class....more

Polsinelli

No Harm, No Foul: The Supreme Court Reduces “Harm” Standard for Discriminatory Job Transfer Claims under Title VII

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In April, the U.S. Supreme Court unanimously held in Muldrow v. City of St. Louis, that to sustain a prima facie case of employment discrimination under Title VII of the Civil Rights Act of 1964 (“Title VII”), plaintiffs do...more

McAfee & Taft

Is being criticized by your supervisor ‘some harm’ and, therefore, discriminatory?

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The recent U.S. Supreme Court decision in Muldrow v. City of St. Louis appears to have expanded the universe of “adverse employment actions” that could support an employee’s discrimination claim. The Supreme Court stated in...more

Troutman Pepper Locke

High Court Update: Recent US Supreme Court Rulings Employers Should Know About

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Thus far, 2024 has been a whirlwind of new employment rules, statutes, guidance, and decisions for employers to grapple with and account for in their businesses. Among these decisions are a handful of rulings from the Supreme...more

Franczek P.C.

Recent Supreme Court Decision Clarifies Lower Standard of Harm for Job Transfers under Title VII

Franczek P.C. on

In a recent decision, Muldrow v. City of St. Louis, the U.S. Supreme Court clarified the standard for determining whether an adverse employment action is a sufficient basis for a discrimination claim under Title VII of the...more

Saul Ewing LLP

Employees No Longer Required to Prove Significant Harm for Title VII Claims

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Under the recent Supreme Court Ruling of Muldrow v. City of St. Louis, employees no longer need to suffer “significant” harm to state a claim of discrimination under Title VII of the Civil Rights Act of 1964 (“Title VII”)....more

Kohrman Jackson & Krantz LLP

Sixth Circuit Rules That Accommodation Requests Under the ADA Can Be Inferred Without Explicit Employee Request

Following the U.S. Supreme Court’s decision in Muldrow v. City of St. Louis, which lowered the threshold for employees to demonstrate discrimination under Title VII, the Sixth Circuit has expanded the scope of what employers...more

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