On April 17, 2024, the U.S. Supreme Court resolved a circuit split by holding that while an employee challenging an allegedly discriminatory job transfer under Title VII of the Civil Rights Act of 1964 must show that the transfer caused some identifiable disadvantage, the disadvantage need not be significant.
The allegations underlying the Muldrow v. City of St. Louis, Missouri opinion involved Jatonya Muldrow, a female police sergeant who, after working on high-profile matters in the specialized Intelligence Division of the St. Louis Police Department for several years, was transferred against her wishes to a uniformed job supervising the day-to-day activities of neighborhood patrol officers. Although her rank and pay remained the same in the new position, her duties, perks and work schedule changed. Muldrow filed suit against the City, alleging that she had suffered sex discrimination because of the involuntary transfer due to her supervisor wanting to hire a male for her job.
Read on for more information in this blog post.
