Muldrow v. City of St. Louis
601 U.S. 346
| SCOTUS | 2024Background
- Jatonya Clayborn Muldrow, a sergeant with the St. Louis Police Department, was involuntarily transferred in 2017 from a plainclothes role in the Intelligence Division to a uniformed supervisory position in a different district.
- The transfer did not affect her rank or pay, but altered her job responsibilities, took away her FBI status, unmarked vehicle, and regular weekday schedule.
- The new Intelligence Division commander wanted to replace Muldrow with a male officer for what he considered “dangerous” work.
- Muldrow filed suit under Title VII, alleging sex discrimination affecting the terms or conditions of employment.
- Lower courts (district and Eighth Circuit) granted summary judgment to the City, holding that Muldrow did not show a "significant" disadvantage since her title, pay, and benefits remained the same.
- Supreme Court granted certiorari to resolve a split over whether an employee must show a “significant” harm to challenge a transfer under Title VII.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does Title VII require a showing of "significant" harm in a discriminatory transfer claim? | Muldrow: Title VII only requires some harm to terms or conditions of employment due to discrimination, not a high threshold of significance. | City: Title VII requires a "significant" or material disadvantage; minor or non-economic changes are not enough. | No heightened threshold; only some harm (not "significant") to employment terms/conditions is needed. |
| Do transfers that do not affect pay or rank fall under Title VII if motivated by discrimination? | Muldrow: Yes, if job responsibilities or work conditions worsen based on sex, it's actionable. | City: No, absent harm to pay, rank or objective conditions, a claim should not proceed. | Such transfers are covered if they harm identifiable terms or conditions of employment due to discrimination. |
| Should concepts from retaliation cases (significant/material adversity) apply to discrimination claims? | Muldrow: Retaliation requirements are context-specific and don't apply to discrimination claims. | City: Yes; parallels in statutory text justify similar thresholds for both. | No; anti-discrimination claims do not require the elevated standard used in retaliation claims. |
| Should policy concerns (frivolous litigation) affect the standard under Title VII? | Muldrow: Statutory text controls; courts can handle meritless claims. | City: Without a higher bar, courts and employers will be burdened. | Policy fears do not override statutory text; courts will not impose extra-textual requirements. |
Key Cases Cited
- United States v. Detroit Timber & Lumber Co., 200 U.S. 321 (explaining that case syllabi do not form part of Supreme Court opinions)
- Oncale v. Sundowner Offshore Services, Inc., 523 U.S. 75 (defining "discriminate against" in Title VII and clarifying coverage beyond economic harms)
- Bostock v. Clayton County, 590 U.S. 644 (discussing adverse actions and Title VII’s prohibition on discrimination)
- Meritor Savings Bank, FSB v. Vinson, 477 U.S. 57 (clarifying "terms and conditions" under Title VII extend beyond the contractual or economic)
- Burlington N. & Santa Fe Ry. Co. v. White, 548 U.S. 53 (establishing a higher harm threshold in retaliation claims—not imported here)