Muldrow v. City of St. Louis
601 U.S. 346, 144 S. Ct. 967, 218 L. Ed. 2d 322 (2024)
Supreme Court of the United States · April 17, 2024
What the court decided
A police sergeant was transferred out of a specialized intelligence unit to a uniformed patrol job, allegedly because she is a woman. Her pay and rank stayed the same, but she lost her FBI task-force status, a take-home car, and a regular weekday schedule. The Supreme Court held that Title VII requires a worker challenging a transfer to show "some harm respecting an identifiable term or condition of employment," but not that the harm was "significant," "serious" or "substantial." The Court distinguished retaliation claims, where the action must be serious enough that it "well might have dissuaded a reasonable worker" from complaining.
Who won
The employee won this round. The Court vacated the judgment for the City and sent the case back. Three Justices concurred only in the judgment.
Why it matters for workers
A discriminatory transfer or change in duties can be illegal even if your pay and title stay the same. You need to show it left you worse off, not that it was a disaster.
Key passage: 601 U.S. 346 at 354-59.
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