Blog Elements - Kitzer Rochel PLLP

On April 26, 2024, Phillip Kitzer co-presented at the Eighth Circuit chapter of the National Employment Lawyers Association conference in Des Moines, Iowa, along with attorney David Albrecht of Fiedler Law Firm. Their session, titled “Eighth Circuit Case Law Update,” offered a comprehensive review of important court decisions affecting employees at the district, appellate, and Supreme Court levels. Their presentation helped employment attorneys throughout the Eighth Circuit better understand the key legal changes and how they impact the field of employment law.

Phillip is a regular presenter at state, regional, and national employment conferences. If you have questions about Minnesota employment law and how recent court decisions may affect you, contact us today.

U.S. Supreme Court Issues Major Victory in Sex Discrimination Case, Lowering the Standard for Proving Discrimination

April 18, 2024/in Blog, Employment, News

On April 17, 2024, the U.S. Supreme Court issued a landmark ruling clarifying that any discriminatory treatment of an employee violates Title VII. The Court ruled in favor of an employee, Sergeant Jatonya Clayborn Muldrow, in her sex discrimination case against the City of St. Louis. Muldrow, who worked as a plainclothes officer in the St. Louis Police Department’s Intelligence Division, was transferred to a uniformed job in the Fifth District against her wishes. She alleged that the transfer was due to her being a woman and that it negatively impacted her employment terms and conditions.

The lower courts had rejected Muldrow’s claim, stating that she needed to show that the transfer caused a “significant” employment disadvantage. However, the Supreme Court rejected this approach, stating that Title VII’s text does not establish such a high bar for proving harm in a discrimination case.

Justice Kagan, who delivered the opinion of the Court, emphasized that while an employee must show some harm from a forced transfer (or other type of employment action) to prevail in a Title VII suit, they need not show that the injury satisfies any sort of significance test. The Court vacated the judgment of the Court of Appeals for the Eighth Circuit and remanded the case for further proceedings consistent with its opinion.

This decision is a major victory for employees who face discrimination in the workplace, as it clarifies that they do not need to meet an elevated threshold of harm to pursue a Title VII claim. The Supreme Court’s ruling reinforces the importance of protecting workers from discriminatory practices that adversely affect their employment terms and conditions, regardless of the perceived significance of the harm caused.

If you have questions about the Muldrow decision, gender discrimination, or employment law generally, please contact us today.

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