The Supreme Court unanimously vacated a decision that requires discriminated employees to demonstrate a “materially significant” disadvantage for discrimination claims. The Court held that employees, under Title VII of the Civil Human Rights Act of 1964 (Title VII), must only show some harm with respect to “an identifiable term or condition of their employment”, but that harm need not be significant.
The Supreme Court’s decision stems from Muldrow v. City of St. Louis, Missouri, a lawsuit brought by a female police officer who was transferred to another department. Her original position was then filled by a male officer. Despite her rank and pay remaining the same, her responsibilities, perks, and work schedule were altered. Muldrow filed a sex discrimination claim under Title VII.
In the lower courts, the District Court granted Summary Judgment in favor of the Defendants, citing that Muldrow was required to show that her position transfer caused a materially significant disadvantage, but that she failed to do so. The Court of Appeals affirmed this ruling. The matter was brought before the Supreme Court who granted writ of certiorari.
Justice Kagan, writing the opinion on behalf of the Court, stated that the term “discriminate against” – as it relates to Title VII – “merely means to treat worse” and it doesn’t automatically elevate the threshold of harm required to pursue a discrimination claim. The Court held that raising the standard of harm would be “adding words to the statute Congress enacted” that it did not intend.
This landmark decision by the Supreme Court will have a major impact on the ability for employees to raise discrimination claims and will strengthen protections for employees. The Supreme Court does not believe that this decision will “open the floodgates” to substantially more Title VII litigation due to the courts’ ability to “dispose of meritless claims.” One available alternative is the Equal Opportunity Employment Commission’s (EEOC) requirement for all discrimination claims to first go through investigation by the agency. Charging Parties must be granted a “right-to-sue” by the agency in order to file a civil action with the courts.
Potomac Legal Group will be monitoring the impacts of this Supreme Court decision closely. If you have questions regarding how this decision affects your employment discrimination claims, contact our Firm’s employment law attorneys for expert legal guidance.
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